CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT 

TABLE OF CONTENTS 

3.1 INTRODUCTION.................................................................................................................3-5
 

3.2 PRODUCT DEFINITIONS..................................................................................................3-5
 

3.3 PRODUCT CLASSES..........................................................................................................3-5
 

3.4 PRODUCT TEST PROCEDURES .....................................................................................3-7
 

3.5 MANUFACTURER TRADE GROUPS .......................................................................... 3-13
 

3.5.1 Association of Home Appliance Manufacturers .............................................................. 3-14
 

3.5.2 Air Conditioning, Heating, and Refrigeration Institute ................................................... 3-14
 

3.6 MANUFACTURER INFORMATION ............................................................................ 3-14
 

3.6.1 Manufacturers and Market Shares .................................................................................... 3-15
 

3.6.2 Mergers and Acquisitions .................................................................................................. 3-20
 

3.6.3 Small Business Impacts ..................................................................................................... 3-22
 

3.6.4 Distribution Channels ........................................................................................................ 3-23
 

3.7 REGULATORY PROGRAMS......................................................................................... 3-23
 

3.7.1 Current Federal Energy Conservation Standards ............................................................. 3-24
 

3.7.2 Energy Independence and Security Act of 2007 .............................................................. 3-25
 

3.7.3 State Energy Conservation Standards............................................................................... 3-26
 

3.7.4 Canadian Energy Conservation Standards........................................................................ 3-26
 

3.7.5 International Standby Power Regulatory Programs......................................................... 3-27
 

3.8 VOLUNTARY PROGRAMS ........................................................................................... 3-29
 

3.8.1 Consortium for Energy Efficiency .................................................................................... 3-29
 

3.8.2 ENERGY STAR ................................................................................................................ 3-30
 

3.8.3 Federal Energy Management Program ............................................................................. 3-31
 

3.8.4 Rebates for Highly Energy-Efficient Products................................................................. 3-32
 

3.9 HISTORICAL SHIPMENTS ............................................................................................ 3-33
 

3.9.1 New Home Starts ............................................................................................................... 3-33
 

3.9.2 Unit Shipments ................................................................................................................... 3-34
 

3.9.3 Value of Shipments............................................................................................................ 3-36
 

3.9.4 Imports and Exports ........................................................................................................... 3-38
 

3.10 HISTORICAL EFFICIENCIES ........................................................................................ 3-40
 

3.11 MARKET SATURATION................................................................................................ 3-41
 

3.12 PRODUCT RETAIL PRICES........................................................................................... 3-41
 

3.13 INDUSTRY COST STRUCTURE ................................................................................... 3-50
 

3.14 INVENTORY LEVELS AND CAPACITY UTILIZATION RATES........................... 3-56
 

3.15 TECHNOLOGY ASSESSMENT..................................................................................... 3-58
 

3.15.1 Product Operations and Component ................................................................................. 3-58
 

3.15.1.1 Residential Clothes Dryers ............................................................................. 3-58
 

3.15.1.2 Room Air Conditioners................................................................................... 3-59
 

3.15.2 Technology Options........................................................................................................... 3-61
 

3.15.2.1 Residential Clothes Dryers ............................................................................. 3-61
 

3.15.2.2 Room Air Conditioners................................................................................... 3-72
 

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3.15.3 Energy Efficiency............................................................................................................... 3-86
 

3.15.3.1 Residential Clothes Dryers ............................................................................. 3-87
 

3.15.3.2 Room Air Conditioners................................................................................... 3-90
 

LIST OF TABLES 

Table 3.3.1 Residential Clothes Dryer Product Classes..................................................................3-6
 

Table 3.3.2 Room Air Conditioner Product Classes .......................................................................3-7
 

Table 3.6.1 Major and Other Residential Clothes Dryer Manufacturers .................................... 3-15
 

Table 3.6.2 2000-2008 Electric Clothes Dryer Manufacturer Market Share ............................. 3-17
 

Table 3.6.3 2000-2008 Gas Clothes Dryer Manufacturer Market Share ................................... 3-18
 

Table 3.6.4 Major and Other Room Air Conditioner Manufacturers.......................................... 3-18
 

Table 3.6.5 2000-2008 Room Air Conditioner Manufacturer Market Share ............................ 3-19
 

Table 3.6.6 Core Appliance Manufacturers .................................................................................. 3-20
 

Table 3.6.7 Major Appliance Sales by Channel (Purchased between 2001 and 2005).............. 3-23
 

Table 3.7.1 Federal Energy Conservation Standards for Residential Clothes Dryers................ 3-24
 

Table 3.7.2 Federal Energy Conservation Standards for Room Air Conditioners ..................... 3-25
 

Table 3.7.3: Canada’s Proposed Efficiency Requirements for Room Air Conditioners............ 3-27
 

Table 3.8.1 CEE Criteria for Room Air Conditioners.................................................................. 3-30
 

Table 3.8.2 ENERGY STAR Criteria for Room Air Conditioners ............................................. 3-31
 

Table 3.8.3 FEMP Recommendations for Room Air Conditioners ............................................ 3-32
 

Table 3.8.4 Rebates Offered for Highly Energy Efficient Room Air Conditioners in 2008 ..... 3-32
 

Table 3.9.1 Industry Shipments of Residential Clothes Dryers (Domestic and Import, in
 

Thousands of Units)............................................................................................... 3-35
 

Table 3.9.2 Industry Shipments of Room Air Conditioners (Domestic and Import, in
 

Thousands of Units)............................................................................................... 3-35
 

Table 3.9.3 ENERGY STAR Shipments for Room Air Conditioners (Domestic and
 

Import) .................................................................................................................... 3-36
 

Table 3.9.4 Household Laundry Equipment Value of Shipments by Year................................. 3-37
 

Table 3.9.5 “Room Air-Conditioners and Dehumidifiers, Except Portable Dehumidifiers”
 

Product Class Value of Shipments by Year ......................................................... 3-37
 

Table 3.9.6 Disposition of Previous Appliance (Percentage) ...................................................... 3-38
 

Table 3.9.7 2008-2009 Imports of Appliances Covered by this Rulemaking ............................ 3-39
 

Table 3.9.8 2007-2008 Exports of Appliances Covered by this Rulemaking ............................ 3-40
 

Table 3.10.1 Room Air Conditioner Energy Efficiency and Consumption Trends
 

(Shipment Weighted Averages)............................................................................ 3-41
 

Table 3.11.1 Appliance Saturation (Number in Millions and Percentage of U.S.
 

Households with Product) ..................................................................................... 3-41
 

Table 3.12.1 Residential Appliance Retail Prices ........................................................................ 3-42
 

Table 3.13.1 Household Appliance Industry Employment and Earnings .................................. 3-51
 

Table 3.13.2 Household Laundry Industry Employment and Earnings ..................................... 3-51
 

Table 3.13.3 Air-Conditioning & Warm Air Heating & Commercial/Industrial
 

Refrigeration Equipment Industry Employment and Earnings .......................... 3-52
 

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Table 3.13.4 Household Appliance Industry Census Data .......................................................... 3-52
 

Table 3.13.5 Household Laundry Industry Census Data ............................................................ 3-54
 

Table 3.13.6 Air Conditioning & Warm Air Heating & Commercial/Industrial
 

Refrigeration Equipment Industry Census Data .................................................. 3-54
 

Table 3.13.7 Industry Cost Structure Using SEC Data ................................................................ 3-55
 

Table 3.14.1 Household Appliance Industry Census Data .......................................................... 3-56
 

Table 3.14.2 Household Laundry Industry Census Data ............................................................. 3-57
 

Table 3.14.3 Air Conditioning & Warm Air Heating & Commercial/Industrial
 

Refrigeration Equipment Industry Census Data .................................................. 3-57
 

Table 3.14.4 Full Production Capacity Utilization Rates............................................................. 3-58
 

Table 3.15.1 Technology Options for Residential Clothes Dryers.............................................. 3-62
 

Table 3.15.2 Technology Options for Room Air Conditioners ................................................... 3-73
 

Table 3.15.3 Manufacturer Test Results from 1997 TSD Analysis: Performance 


Improvements due to Subcoolers.......................................................................... 3-77
 

Table 3.15.4 Residential Clothes Dryer Market Share Efficiency Data for Electric
 

Standard Dryers ..................................................................................................... 3-89
 

Table 3.15.5 Residential Clothes Dryer Market Share Efficiency Data for Gas Dryers............ 3-89
 

Table 3.15.6 RAC Models of Interest for Max-Tech Analysis, as Listed in the ENERGYSTAR and CEC Listings ....................................................................................... 3-97
 

Table 3.15.7 Selected Product Ratings in NRCan Directory ....................................................... 3-98
 

LIST OF FIGURES 

Figure 3.6.2 2008 Market Shares for the Domestic Electric Clothes Dryer Market .................. 3-16
 

Figure 3.6.3 2008 Market Shares for the Domestic Gas Clothes Dryer Market......................... 3-17
 

Figure 3.6.4 2008 Market Shares for the Domestic Room Air Conditioner Market .................. 3-19
 

Figure 3.6.5 2008 Core Appliance Market Shares ....................................................................... 3-21
 

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

in the United States from 1998–2009 .................................................................. 3-34
 

Figure 3.12.1 Retail Prices for Room Air Conditioners, Product Classes 1 through 5 .............. 3-43
 

Figure 3.12.2 Retail Prices for Room Air Conditioners, Product Classes 6 through 10 ............ 3-44
 

Figure 3.12.3 Retail Price versus EER for Product Class 1 ......................................................... 3-45
 

Figure 3.12.4 Retail Price versus EER for Product Class 2 ......................................................... 3-46
 

Figure 3.12.5 Retail Price versus EER for Product Class 3 ......................................................... 3-47
 

Figure 3.12.6 Retail Price versus EER for Product Class 4 ......................................................... 3-48
 

Figure 3.12.7 Retail Price versus EER for Product Class 5 ......................................................... 3-49
 

Figure 3.12.8 Retail Price versus EER for Product Class 8 ......................................................... 3-50
 

Figure 3.13.1 Industry Gross Margin Derived from SEC Data ................................................... 3-55
 

Figure 3.15.1 Room Air Conditioner Operation Schematic ........................................................ 3-61
 

Figure 3.15.2. Modeling of R-407C compared to R-410A......................................................... 3-85
 

Figure 3.15.3 Electric Standard Capacity Clothes Dryers in the CEC Directory ....................... 3-87
 

Figure 3.15.4 Electric Compact Capacity Clothes Dryers in the CEC Directory....................... 3-88
 

Figure 3.15.5 Gas Clothes Dryers in the CEC Directory ............................................................. 3-89
 

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Figure 3.15.6 CEC, AHAM, and ENERGY STAR Certified Room Air Conditioners
 

without Reverse Cycle and with Louvered Sides (Product Classes 1–5), , ....... 3-91
 

Figure 3.15.7 CEC, AHAM, and ENERGY STAR Certified Room Air Conditioners
 

without Reverse Cycle and without Louvered Sides (Product Classes 6–
 

10),,

 ......................................................................................................................... 3-92
 

Figure 3.15.8 CEC, AHAM, and ENERGY STAR Certified Room Air Conditioners with
 

Reverse Cycle (Product Classes 11–14),, ............................................................ 3-93
 

Figure 3.15.9 CEC, AHAM, and ENERGY STAR Certified Room Air Conditioners
 

Figure 3.15.10 Distribution of Room Air Conditioner Models in the CEC, AHAM, and
 

Figure 3.15.11. R-410A Room Air Conditioners without Reverse Cycle and with
 

Figure 3.15.12. R-410A Room Air Conditioners without Reverse Cycle and with
 

Casement-Only and Casement-Slider (Product Classes 15, 16),, ...................... 3-94
 

ENERGY STAR Databases,, ................................................................................ 3-95
 

Louvered Sides (Product Classes 1–5) ................................................................. 3-96
 

Louvered Sides (Product Classes 1–5) ................................................................. 3-97
 

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CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT
 

3.1 INTRODUCTION
 

This chapter provides a profile of the residential clothes dryer and room air conditioner 

industries in the United States. The U.S. Department of Energy (DOE) developed the market and 

technology assessment presented in this chapter primarily from publicly available information. 

This assessment is helpful in identifying the major manufacturers and their product 

characteristics, which form the basis for the engineering and the life-cycle cost (LCC) analyses. 

Present and past industry structure and industry financial information help DOE in the process of 

conducting the manufacturer impact analysis. 

3.2 PRODUCT DEFINITIONS 

DOE defines “electric clothes dryer” under the Energy Policy and Conservation Act 

(EPCA) of 1975, Pub. L. 94-163, (42 United States Code (U.S.C.) 6291–6309) as “a cabinet-like 

appliance designed to dry fabrics in a tumble-type drum with forced air circulation. The heat 

source is electricity and the drum and blower(s) are driven by an electric motor(s).” Similarly, 

EPCA defines “gas clothes dryer” as “a cabinet-like appliance designed to dry fabrics in a 

tumble-type drum with forced air circulation. The heat source is gas and the drum and blower(s) 

are driven by an electric motor(s).” (10 Code of Federal Regulation (CFR) 430.2) 

DOE defines “room air conditioner” under EPCA as “a consumer product, other than a 

“packaged terminal air conditioner”, which is powered by a single phase electric current and 

which is an encased assembly designed as a unit for mounting in a window or through the wall 

for the purpose of providing delivery of conditioned air to an enclosed space. It includes a prime 

source of refrigeration and may include a means for ventilating and heating.” (10 CFR 430.2) 

3.3 PRODUCT CLASSES 

DOE has established separate product classes for each product (residential clothes dryers 

and room air conditioners). DOE formulates a separate energy conservation standard for each 

product class. As required by EPCA, the criteria for separation into different classes are: (1) type 

of energy used, or (2) capacity or other performance-related features such as those that provide 

utility to the consumer or others deemed appropriate by the Secretary that would justify the 

establishment of a separate energy conservation standard. (42 U.S.C. 6295 (q) and 6316(a))

 For residential clothes dryers, DOE considered four product classes for vented and two 

product classes for ventless dryers, as shown in Table 3.3.1. This is a new analytical structure for 

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clothes dryers, recognizing the unique utility that ventless clothes dryers offer to consumers.a 

Another new entry with unique utility is the combination washer/dryer (i.e., a device which 

washes and then dries clothes in the same basket/cavity in a combined cycle). Combination 

washer/dryers are very popular in space-constrained environments (e.g., apartments, recreational 

vehicles), and all products of this type appear to utilize ventless operation. Thus, like other 

ventless dryers, such combination washer/dryers can be installed in locations where venting 

dryers would be precluded due to venting restrictions. As discussed in section 0, DOE published 

a test procedure final rule amending the DOE test procedure for clothes dryers to include 

provisions for testing of ventless clothes dryers. Therefore, DOE included product classes for 

ventless clothes dryers in this rulemaking analysis. 

Table 3.3.1 Residential Clothes Dryer Product Classes 

Vented dryers 

1. Electric, Standard (4.4 cubic feet (ft3) or greater capacity) 

2. Electric, Compact (120 volts (V)) (less than 4.4 ft3 capacity) 

3. Electric, Compact (240 V) (less than 4.4 ft3 capacity) 

4. Gas 

Ventless dryers 

5. Electric, Compact (240 V) (less than 4.4 ft3 capacity) 

6. Electric, Combination Washer/Dryer

 For room air conditioners, amendments to EPCA in the National Appliance Energy 

Conservation Act of 1987 (NAECA), Pub. L. 100-12, initially specified 12 product classes which 

were applicable to units designed for single- or double-hung window installation or through-thewall installation and based on the following criteria: (1) cooling capacity; (2) the presence of 

louvered sides (LS); and (3) the capability of reverse cycle (i.e., the unit can function as a heat 

pump). (42 U.S.C. 6295(c)(1)) Capacity is measured in British Thermal Units (Btu) per hour (h). 

In the final rule published in the Federal Register on September 24, 1997, DOE established an 

updated set of performance standards (effective October 1, 2000) which included four additional 

product classes.b 

For this final rule, DOE will split product classes 5 and 8 into two product classes each. 

Current product class 5 (louvered, non-reverse-cycle, capacity of 20,000 and higher) will be split 

into product class 5A (louvered, non-reverse-cycle, capacity of 20,000 to 27,999 Btu/h) and 

a

 Previously, DOE has described ventless dryers as condensing dryers. The new designation reflects the actual 

consumer utility (i.e., no external vent required) and the market availability of vented dryers that also condense. 

b

 DOE divided the product class covering units with reverse cycle and with louvered sides into units of capacity less 

than 20,000 Btu/h and units 20,000 Btu/h or more. DOE split the product class covering units with reverse cycle and 

without louvered sides into units of capacity less than 14,000 Btu/h and units 14,000 Btu/h or more. In addition, 

DOE established two new product classes for units that are designed to be installed in casement-slider and casementonly windows. Due to the size constraints imposed by casement windows, casement units are small in size and 

typically deliver 5,000 to 10,000 Btu/h in cooling capacity. 

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product class 5B (Louvered, non-reverse-cycle, capacity of 28,000 and higher). Product class 8 

(non-louvered, non-reverse-cycle, capacity of 8,000 to 13,999 Btu/h) will be split into product 

class 8A (non-louvered, non-reverse-cycle, capacity of 8,000 to 10,999 Btu/h) and 8B (nonlouvered, non-reverse-cycle, capacity of 11,000 to 13,999 Btu/h). These product class changes 

are discussed in greater detail in section 5.9.2.11 in chapter 5 of this technical support document 

(TSD). Table 3.3.2 lists the 18 product classes for room air conditioners. 

Table 3.3.2 Room Air Conditioner Product Classes 

Without reverse cycle and with louvered sides 

1. Less than 6,000 Btu/h 

2. 6,000 to 7,999 Btu/h 

3. 8,000 to 13,999 Btu/h 

4. 14,000 to 19,999 Btu/h 

5A. 20,000 to 27,999 Btu/h 

5B. 28,000 Btu/h or more 

Without reverse cycle and without louvered sides 

6. Less than 6,000 Btu/h 

7. 6,000 to 7,999 Btu/h 

8A. 8,000 to 10,999 Btu/h 

8B. 11,000 to 13,999 Btu/h 

9. 14,000 to 19,999 Btu/h 

10. 20,000 Btu/h or more 

With reverse cycle 

11. With louvered sides and less than 20,000 Btu/h 

12. Without louvered sides and less than 14,000 Btu/h 

13. With louvered sides and 20,000 Btu/h or more 

14. Without louvered sides and 14,000 Btu/h or more 

Casement 

15. Casement-Only 

16. Casement-Slide 

3.4 PRODUCT TEST PROCEDURES 

Test procedures exist for both products covered by this rulemaking to determine energy 

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

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

dryers and room air conditioners through the rulemaking process, in both cases over 25 years 

ago. The Energy Independence and Security Act of 2007 (EISA 2007), Pub. L. 110-140, amends 

EPCA to require DOE to review these test procedures at least every 7 years and to amend them if 

such amended test procedures would more accurately or fully comply with the requirements of 

producing test results which measure energy efficiency, energy use, or estimated annual 

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operating cost during a representative average use cycle or period of use without being unduly 

burdensome to conduct. (42 U.S.C. 6293(b)(1)) 

DOE originally established its test procedure for residential clothes dryers in a final rule 

published in the Federal Register on September 14, 1977. (42 FR 46145; 10 CFR part 430, 

subpart B, appendix D) On May 19, 1981 DOE published a final rule to amend the test 

procedure by establishing a field-use factor for clothes dryers with automatic termination 

controls, clarifying the test cloth specifications and clothes dryer preconditioning, and making 

editorial and minor technical changes. 46 FR 27324. The clothes dryer test procedure cited two 

industry test standards: (1) the Association of Home Appliance Manufacturers (AHAM) 

Standard HLD-1-1974, AHAM Performance Evaluation Procedure for Household Tumble Type 

Clothes Dryers and (2) AHAM Standard HLD-2EC, Test Method for Measuring Energy 

Consumption of Household Tumble Type Clothes Dryers, December 1975. 

DOE redesignated and amended its test procedure for room air conditioners on June 29, 

1979. (44 FR 37938; 10 CFR part 430, subpart B, appendix F) The current room air conditioner 

test procedure cites two test standards that are each at least 25 years old: (1) American National 

Standards (since renamed American National Standards Institute (ANSI)) Z234.1-1972, Room 

Air Conditioners and (2) American Society of Heating, Refrigerating and Air-Conditioning 

Engineers (ASHRAE) Standard 16-69, Method of Testing for Rating Room Air Conditioners. 

Standby power measurement is not currently incorporated into DOE test procedures for 

residential clothes dryers or room air conditioners. Section 310 of EISA 2007 amended Section 

325 of EPCA to require that the test procedures for clothes dryers and room air conditioners be 

amended to include measurement of standby mode and off mode power, taking into 

consideration the most current version of International Electrotechnical Commission (IEC) 

Standard 62301 Household electrical appliances – Measurement of standby power (IEC 

Standard 62301).c

 EPCA, as amended by EISA 2007, also required that the final rule for this test 

procedure be published no later than March 31, 2009. (42 U.S.C. 6295(gg)) DOE initiated a 

separate test procedure rulemaking to modify the test procedures for clothes dryers and room air 

conditioners to provide procedures for the measurement of standby and off modes. DOE 

published a NOPR for this rule on December 9, 2008 (December 2008 TP NOPR). 73 FR 74639. 

DOE determined after the December 2008 TP NOPR was published that it would 

consider a revised version of IEC Standard 62301, i.e., IEC Standard 62301 Second Edition, 

which at that time was expected to be published in July 2009. DOE anticipated, based on review 

of drafts of the updated IEC Standard 62301, that the revisions could include different mode 

definitions. Subsequently, DOE received information that IEC Standard 62301 Second Edition 

c

 DOE notes that EPCA as amended by EISA 2007, also requires DOE to consider IEC Standard 62087, which 

specifies methods of measurement for the power consumption of TV receivers, VCRs, set top boxes, audio 

equipment and multi-function equipment for consumer use. IEC Standard 62087 does not, however, include 

measurement for the power consumption of electrical appliances such as clothes dryers and room air conditioners. 

Therefore, DOE determined that IEC Standard 62087 was not suitable for amendments to the clothes dryer and 

room air conditioner test procedures. 

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would not be published until late 2010. To allow for the consideration of standby and off mode 

power consumption in this energy conservation standards rulemaking, DOE published a SNOPR 

on June 29, 2010 (June 2010 TP SNOPR), proposing mode definitions based on the new mode 

definitions from the most recent draft version of IEC Standard 62301 Second Edition which, at 

that time, was designated as IEC Standard 62301 Second Edition Committee Draft for Vote (IEC 

Standard 62301 CDV). 75 FR 37594. The IEC circulated IEC Standard 62301 CDV on August 

28, 2009. IEC Standard 62301 CDV contained the most recent proposed amendments to IEC 

Standard 62301, including new mode definitions, at the time the June 2010 TP SNOPR was 

issued. IEC Standard 62301 CDV revised the proposed mode definitions from previous draft 

versions of IEC Standard 62301 and addressed comments received by interested parties in 

response to those drafts. As a result, DOE stated in the June 2010 TP SNOPR that the mode 

definitions in IEC Standard 62301 CDV represent the best definitions available for the 

supporting analysis. Id. 

DOE also determined after publication of the December 2008 TP NOPR to conduct a 

rulemaking to amend the active mode test procedure for clothes dryers and room air 

conditioners. DOE addressed the test procedure issues relating to active mode for clothes dryers 

and room air conditioners in the June 2010 TP SNOPR. In the June 2010 TP SNOPR, DOE 

proposed the following test procedure amendments for the measurement of active mode energy 

consumption for clothes dryers and room air conditioners: 1) procedures for more accurately 

measuring the effects of different automatic termination technologies in clothes dryers; (2) 

provisions for ventless clothes dryers, which are being considered under an amended energy 

conservation standard; (3) updated detergent specifications for clothes dryer test cloth 

preconditioning; (4) changes to better reflect current usage patterns and capabilities for the 

covered products; (5) updated references to external test procedures; and (6) clarifications to the 

test conditions for gas clothes dryers. 75 FR 37594 (June 29, 2010). 

DOE recently published a final rule in the Federal Register on January 6, 2011, (January 

2011 TP Final Rule) in which it adopted amendments to the clothes dryer and room air 

conditioner test procedures. 76 FR 972. In the January 2011 TP Final Rule, DOE incorporated by 

reference into both the clothes dryer and room air conditioner test procedures specific clauses 

from IEC Standard 62301 First Edition 2005-06 regarding test conditions and test procedures for 

measuring standby and off mode power consumption. DOE also incorporated into each test 

procedure definitions of “active mode,” “standby mode,” and “off mode” that are based on the 

definitions provided in IEC Standard 62301 CDV. Further, DOE adopted language in each test 

procedure to clarify the application of clauses from IEC Standard 62301 First Edition and the 

mode definitions from IEC Standard 62301 CDV for measuring standby and off mode power 

consumption. 76 FR 972, 979–987 (Jan. 6, 2011). 

DOE also notes that EISA 2007 amended EPCA to require that standby mode and off 

mode energy consumption be integrated into the overall energy efficiency, energy consumption, 

or other energy descriptor unless the Secretary determines that – (i) the current test procedures 

for a covered product already fully account for and incorporate standby mode and off mode 

energy consumption of the covered product; or (ii) such an integrated test procedure is 

technically infeasible for a particular covered product, in which case the Secretary shall prescribe 

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a separate standby mode and off mode energy use test procedure for the covered product, if 

technically feasible. (42 U.S.C. 6295(gg)(2)(A)) For both clothes dryers and room air 

conditioners, DOE determined in the January 2011 TP Final Rule that it is technically feasible to 

incorporate standby mode and off mode energy consumption into overall energy consumption. 

As a result, DOE adopted new methods to calculate clothes dryer and room air conditioner 

standby and off mode energy use and a new measure of energy efficiency (Combined Energy 

Factor (CEF) and Combined Energy Efficiency Ratio (CEER), respectively) that integrates 

standby and off mode energy use with the active mode energy use for both products. 76 FR 972, 

991–992 (Jan. 6, 2011). Accordingly, DOE developed the amended energy conservation 

standards for residential clothes dryers and room air conditioners based on these integrated 

metrics. 

Concerning the active mode, DOE adopted amendments in the January 2011 TP Final 

Rule to the clothes dryer test procedure to include the provisions for testing ventless clothes 

dryers proposed in the June 2010 TP SNOPR. These amendments consisted of adding separate 

definitions for a “conventional clothes dryer” (vented) and a “ventless clothes dryer”. Further, 

the alternate test procedure qualifies the requirement for an exhaust simulator so that it would 

only apply to conventional clothes dryers. DOE also adopted provisions to clarify the testing 

procedures for ventless clothes dryers, including requirements for clothes dryers equipped with a 

condensation box, requirements for the condenser heat exchanger, and specifications for ventless 

clothes dryer preconditioning. In addition to the amendments proposed in the June 2010 TP 

SNOPR, DOE adopted clarifications in the January 2011 TP Final Rule to provide explicit 

instructions as to the procedure for re-running the test cycle when the condensation box is full. 

DOE also revised the requirement for ventless clothes dryer preconditioning to remove the 

maximum time limit for achieving a steady-state temperature. DOE also included additional 

editorial clarifications to the testing procedures for ventless clothes dryers. 76 FR 972, 1003–09 

(Jan. 6, 2011). 

In addition, DOE amended the clothes dryer test procedure to reflect current usage 

patterns and capabilities. These amendments were based on DOE’s analysis of consumer usage 

patterns data. DOE revised the number of annual use cycles from 416 cycles per year to 283 

cycles per year for all types (i.e., product classes) of clothes dryers. This revision was based on 

DOE’s analysis of data from the Energy Information Administration (EIA)’s 2005 Residential 

Energy Consumption Survey (RECS)d

,

e for the number of laundry loads (clothes washer cycles) 

washed per week and the frequency of clothes dryer use. In the June 2010 TP SNOPR, DOE 

proposed to revise the 70-percent initial remaining moisture content (RMC) required by the test 

procedure to 47 percent so as to accurately represent the condition of laundry loads after a wash 

cycle. This proposal was based on analysis of shipment-weighted RMC data for clothes washers 

submitted by the Association of Home Appliance Manufacturers (AHAM) and based on a 

distribution analysis of RMC values for clothes washer models listed in the December 22, 2008, 

d

 U.S. Department of Energy-Energy Information Administration. Residential Energy Consumption Survey, 2005 

Public Use Data Files, 2005. Washington, DC. Available online at: http://www.eia.doe.gov/emeu/recs/ 

e EIA’s 2005 RECS is the latest available version of this survey. 

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California Energy Commission (CEC) directory. 75 FR 37594, 37599 (June 29, 2010). Based on 

comments from interested parties, DOE determined that an initial clothes dryer RMC of 57.5 

percent more accurately represents the moisture content of laundry loads after a wash cycle for 

the purposes of clothes dryer testing. This RMC was derived from the 47-percent shipmentweighted RMC for clothes washers, but was derived without applying an RMC correction factor 

as required by the DOE clothes washer test procedure. For these reasons, DOE revised the initial 

clothes dryer RMC from 70 percent to 57.5 percent in the final rule. In addition, DOE changed 

the 7-pound (lb) clothes dryer test load size specified by the current test procedure for standardsize clothes dryers to 8.45 lb. This revision was based on the historical trends of clothes washer 

tub volumes and the corresponding percentage increase in clothes washer test load sizes (as 

specified by the DOE clothes washer test procedure). DOE assumed these historical trends 

proportionally impact dryer load sizes. 76 FR 972, 1010–15 (Jan. 6, 2011). 

Based on the rinse temperature use factors in the DOE clothes washer test procedure and 

2005 RECS data reporting the percentage of clothes washer cycles for which consumers use cold 

water for the rinse cycle, DOE amended the clothes dryer test procedure to change the water 

temperature for clothes dryer test load preparation from 100 degrees Fahrenheit (°F) ± 5°F to 

60°F ± 5°F. This temperature is more representative of the clothes load temperature after a cold 

rinse cycle at the end of the wash cycle. 76 FR 972, 995-997 (Jan. 6, 2011). 

DOE also amended the clothes dryer test procedure to: (1) revise the detergent 

specifications for test cloth preconditioning due to obsolescence of the detergent specified in the 

test procedure, (2) update the reference to the industry test standard, (3) eliminate an unnecessary 

reference to an obsolete industry clothes dryer test standard, (4) amend the provisions in its test 

procedure which specify test conditions for gas clothes dryers to clarify the required gas supply 

pressure, (5) amend the provisions for measuring the drum capacity, (6) amend the provisions for 

the application of the field use factor for automatic cycle termination, and (7) add the 

calculations of energy factor (EF) and CEF to 10 CFR part 430, subpart B, appendix D1. 76 FR 

972, 994, 1009–10, 1017–19 (Jan. 6, 2011). 

In the June 2010 TP SNOPR, DOE proposed amendments to more accurately measure 

automatic cycle termination by accounting for the amount over-drying energy consumption. 75 

FR 37594, 37599 (June 29, 2010). However, DOE conducted testing of representative clothes 

dryers using the automatic cycle termination test procedure proposed in the June 2010 TP 

SNOPR. The test results showed that all of the dryers tested significantly over-dried the DOE 

test load to near bone dry. In addition, the measured EF values were significantly lower than EF 

values obtained using the existing DOE test procedure, and the test data indicated that clothes 

dryers equipped with automatic termination controls were less efficient than timer dryers. DOE 

stated in the January 2011 TP Final Rule that the test procedure amendments for automatic cycle 

termination proposed in the June 2010 TP SNOPR do not adequately measure the energy 

consumption of clothes dryers equipped with such systems using the test load specified in the 

DOE test procedure. DOE believes that clothes dryers with automatic termination sensing 

control systems, which infer the RMC of the load from the properties of the exhaust air such as 

temprature and humidity, may be designed to stop the cycle when the consumer load has a higher 

RMC than the RMC obtained using the proposed automatic cycle termination test procedure in 

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conjunction with the existing test load.f Manufacturers have indicated, however, that test load 

types and test cloth materials different than those specified in the DOE test procedure do not 

produce results as repeatable as those obtained using the test load as currenty specified. In 

addition, DOE presented data in the May 1981 TP Final Rule from a field use survey conducted 

by AHAM as well as an analysis conducted by the National Bureau of Standards (now known as 

the National Institute of Standards and Technology (NIST)) of field test data on automatic 

termination control dryers. Analysis of this data showed that clothes dryers equipped with an 

automatic cycle termination feature consume less energy than timer dryers by reducing overdrying. 46 FR 27324 (May 19, 1981). For these reasons, DOE stated in the January 2011 TP 

Final Rule that the test procedure amendments for automatic cycle termination proposed in the 

June 2010 TP SNOPR do not adequately measure the energy consumption of clothes dryers 

equipped with such systems. As a result, DOE did not adopt the amendments for automatic cycle 

termination proposed in the June 2010 TP SNOPR. 76 FR 972, 993–1003 (Jan. 6, 2011). 

Also as part of the January 2011 TP Final Rule, DOE amended the room air conditioner 

test procedure to update the references to the industry test standards to reference, ANSI/AHAM 

RAC-1-2008, Room Air Conditioners, and ANSI/ASHRAE 16-1983 (RA2009), Method of 

Testing for Rating Room Air Conditioners and Packaged Terminal Air Conditioners, 

respectively. 76 FR 972, 1016–1017 (Jan. 6, 2011). 

In the October 24, 2007 Framework Document, DOE identified two other limitations of 

the room air conditioner test procedure: (1) the inability of the test procedure to measure the 

benefits of technologies that improve part-load performance, and (2) the assumed annual 

operational hours. 

The current room air conditioner test procedure measures only the full-load performance 

at outdoor ambient conditions of 95 oF dry-bulb and 75 oF wet-bulb. Therefore, technologies that 

improve part-load performance, such as multiple-speed compressors and variable-opening 

expansion devices, will not improve the rated performance of a room air conditioner under the 

current test procedure. In contrast, central air conditioners and heat pumps are rated with a 

seasonal energy efficiency ratio (SEER) descriptor, but the test procedure consists of multiple 

rating points that add time and expense when rating the product. 

DOE concluded in the June 2010 TP SNOPR that widespread use of part-load technology 

in room air conditioners would not likely be stimulated by the development of a part-load metric 

at this time, and therefore, the significant effort required to develop an accurate part-load metric 

is not likely to be warranted by the expected minimal energy savings. 75 FR 37594, 37633–34 

f

 To investigate this, DOE conducted additional testing using a test load similar to that specified in AHAM Standard 

HLD-1-2009, which consists of cotton bed sheets, towels, and pillow cases. For tests using the same automatic 

cycle termination settings as were used in the testing described earlier (i.e., normal cycle setting and highest 

temperature setting, the alternate test load was dried to 1.7 to 2.2 percent final RMC, with an average RMC of 2.0 

percent. In comparison, the same clothes dryer under the same cycle settings dried the DOE test load to 0.3 to 1.2 

percent RMC, with an average RMC of 0.7 percent. Thus, DOE concluded that the proposed automatic cycle 

termination control test procedures may not stop at an appropriate RMC when used with the current test load. 

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(June 29, 2010). DOE also noted that the key design changes that improve full-load efficiency 

also improve part-load efficiency, so the existing EER metric is already a strong indication of 

product efficiency over a wide range of conditions. DOE concluded that development of an 

additional test for part load, or a change of the room air conditioner metric to a part-load test, is 

not supported by information available to DOE at this time. Therefore, DOE did not consider 

amendments to its room air conditioner test procedure to measure part-load performance in the 

June 2010 TP SNOPR. 75 FR 37594, 37634 (June 29, 2010).For these reasons, DOE did not 

amend its room air conditioner test procedure to measure part-load performance in the January 

2011 TP Final Rule. 76 FR 972, 1016 (Jan. 6, 2011). 

DOE determined in the January 2011 TP Final Rule that the 750 annual operating hours 

specified by the current DOE room air conditioner test procedure is representative of current 

usage patterns, based upon its analysis of data from the 2005 RECS. Therefore, DOE did not 

amend the annual usage hours specified by the current DOE test procedure for room air 

conditioners. 76 FR 972, 1015–16 (Jan. 6, 2011). 

EPCA requires that DOE must determine to what extent, if any, the proposed test 

procedure would alter the measured energy efficiency of any covered product as determined 

under the existing test procedure. (42 U.S.C. 6293(e)(1)) If DOE determines that the amended 

test procedure would alter the measured efficiency of a covered product, DOE must amend the 

applicable energy conservation standard during the rulemaking carried out with respect to such 

test procedure. In determining the amended energy conservation standard, the Secretary shall 

measure, pursuant to the amended test procedure, the energy efficiency, energy use, or water use 

of a representative sample of covered products that minimally comply with the existing standard. 

(42 U.S.C. 6293(e)(2)) 

Under 42 U.S.C. 6295(gg)(2)(C), EPCA provides that amendments to the test procedures 

to include standby mode and off mode energy consumption will not determine compliance with 

previously established standards. (U.S.C. 6295(gg)(2)(C)) Because the amended test procedures 

for standby mode and off mode energy consumption would not alter existing measures of energy 

consumption or efficiency, these amendments would not affect a manufacturer’s ability to 

demonstrate compliance with previously established standards. 

As discussed in chapter 5 of this TSD, DOE investigated how the amendments to the 

active mode provisions in its clothes dryer and room air conditioner test procedures in the 

January 2011 TP Final Rule affect the measured efficiency of products. 

3.5 MANUFACTURER TRADE GROUPS 

DOE recognizes the importance of trade groups in disseminating information and 

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

clothes dryer and room air conditioner industries, DOE researched various associations available 

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to manufacturers, suppliers, and users of such equipment. DOE also used the member lists of 

these groups in the construction of an exhaustive database containing domestic manufacturers. 

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

clothes dryer and/or room air conditioner industries, including AHAM and the Air Conditioning 

and Refrigeration Institute. 

3.5.1 Association of Home Appliance Manufacturers

 AHAMg

, formed in 1967, aims to enhance the value of the home appliance industry 

through leadership, public education and advocacy. AHAM provides services to its members 

including government relations; certification programs for room air conditioners, dehumidifiers 

and room air cleaners; an active communications program; and technical services and research. 

In addition, AHAM conducts other market and consumer research studies and publishes a 

biennial Major Appliance Fact Book. AHAM also develops and maintains technical standards 

for various appliances to provide uniform, repeatable procedures for measuring specific product 

characteristics and performance features. 

3.5.2 Air Conditioning, Heating, and Refrigeration Institute 

The Air Conditioning, Heating, and Refrigeration Institute (AHRI)h

 is the trade 

organization that represents manufacturers of over 90 percent of the air conditioning and 

refrigeration equipment that is currently installed in the United States. AHRI develops and 

publishes technical standards, often in conjunction with ANSI, the IEC, and the International 

Organization for Standardization (ISO). AHRI maintains a certification program and certified 

product database, and supports legislation, regulations, and codes favorable to the HVACR 

industry. While AHRI does not certify room air conditioners, it represents a number of 

manufacturers which produce multiple types of air conditioning systems, including room air 

conditioners, and is involved with regulatory issues affecting all types of refrigeration-based 

systems. 

3.6 MANUFACTURER INFORMATION 

The following section details information regarding manufacturers of residential clothes 

dryers and room air conditioners for sale in the United States, including estimated market shares 

(section 3.6.1), industry mergers and acquisitions (section 3.6.2), potential small business 

impacts (section 3.6.3), and product distribution channels (section 3.6.4). 

g

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

h

 For more information, please visit http://www.ahrinet.org/ 

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3.6.1 Manufacturers and Market Shares 

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

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

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

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

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

overseas. Companies included in this analysis may also be off-shore manufacturers that maintain 

a significant domestic presence via a U.S. entity.

 For residential clothes dryers, DOE estimates that there are 14 manufacturers selling into 

the domestic market, of which several are foreign-owned companies with manufacturing 

facilities outside of the United States. The majority of market share is held by four major 

domestic manufacturers, including Whirlpool Corporation (Whirlpool), Maytag Corporation 

(Maytag), GE Consumer & Industrial (GE), and AB Electrolux (Frigidaire).1

 As will be 

discussed in section 3.6.2, Maytag and Whirlpool merged in 2006 but have continued to maintain 

both product lines to this date. The combined Maytag-Whirlpool entity accounts for 70 - 74 

percent of the residential clothes dryer market. Other manufacturers include Alliance Laundry 

Systems LLC (Alliance), AM Appliance Group (formerly ASKO, Inc.), BSH Home Appliances 

Corporation (Bosch-Siemens), Fisher & Paykel Appliances Limited (Fisher & Paykel), Haier 

America Trading, LLC (Haier), Indesit Company (Indesit), LG Electronics, Inc. (LG), Miele, 

Inc. (Miele), Samsung Electronics America, Inc. (Samsung), and Felix Storch, Inc. (Summit). 

Table 3.6.1 lists these manufacturers. Figure 3.6.1 and Figure 3.6.2 illustrate the 2008 market 

shares for the domestic residential electric and gas clothes dryer markets, respectively. 

Table 3.6.1 Major and Other Residential Clothes Dryer Manufacturers 

Major Manufacturers Other Manufacturers 

Whirlpool Alliance 

Maytag ASKO 

GE Bosch-Siemens 

Frigidaire Fisher & Paykel 

Haier 

Indesit 

LG 

Miele 

Samsung 

Summit 

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Figure 3.6.1 2008 Market Shares for the Domestic Electric Clothes Dryer Market2 

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Figure 3.6.2 2008 Market Shares for the Domestic Gas Clothes Dryer Market3 

Table 3.6.2 and Table 3.6.3 show the market share for electric and gas clothes dryer 

manufacturers, respectively, between 2000 and 2008. The market shares for the top three clothes 

dryer manufacturers have remained relatively stable since 2000; however, the market share for 

Electrolux gas dryers has decreased by 5 percent since 2000. 

Table 3.6.2 2000-2008 Electric Clothes Dryer Manufacturer Market Share 4 

Company 

Market Share (%) 

2008 2007 2006 2005 2004 2003 2002 2001 2000 

Whirlpool 70* 56 56 56 56 56 55 54 54 

Maytag - 16 17 18 19 18 20 20 19 

GE 16 15 15 14 14 15 17 18 16 

Electrolux (Frigidaire) 8 8 9 10 10 11 8 8 8 

Others 6 5 3 2 1 0 0 0 3 

*Whirlpool share of market in 2008 includes Maytag. 

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Table 3.6.3 2000-2008 Gas Clothes Dryer Manufacturer Market Share 5 

Company 

Market Share (%) 

2008 2007 2006 2005 2004 2003 2002 2001 2000 

Whirlpool 74 55 55 55 55 55 57 58 56 

Maytag - 22 23 25 25 26 23 23 21 

GE 10 11 11 11 11 11 13 13 13 

Electrolux (Frigidaire) 5 5 6 7 7 8 7 6 10 

Others 11 7 5 3 2 0 0 0 0 

*Whirlpool share of market in 2008 includes Maytag.

 For room air conditioners, DOE estimates that there are less than 10 key manufacturers 

supplying the U.S. market. Based on data published by Appliance Magazine,

6

 nearly three 

quarters of the domestic market, 70 percent, in 2008 was controlled by four manufacturers: LG, 

Fedders Corporation (Fedders), Frigidaire, and Whirlpool. The remaining market share was 

divided among companies including Haier, Samsung, Sharp Electronics Corporation (Sharp), 

Friedrich Air Conditioning Company (Friedrich) and others. Table 3.6.4 lists these 

manufacturers. Figure 3.6.3 illustrates the 2008 market shares for the domestic room air 

conditioner market. 

Table 3.6.4 Major and Other Room Air Conditioner Manufacturers 

Major Manufacturers Other Manufacturers 

LG Haier 

Fedders Samsung 

Frigidaire Sharp 

Whirlpool Matsushita 

Friedrich 

Carrier 

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Figure 3.6.3 2008 Market Shares for the Domestic Room Air Conditioner Market6 

Table 3.6.5 shows the market share for room air conditioner manufacturers between 2000 

and 2008. The market share for LG increased 12 percent since 2000, whereas the market share 

for Fedders and Electrolux dropped by 10 and 4 percent, respectively, over the same period. 

Whirlpool’s market share remained relatively stable between 2000 and 2008. 

Table 3.6.5 2000-2008 Room Air Conditioner Manufacturer Market Share 7 

Company 

Market Share (%) 

2008 2007 2006 2005 2004 2003 2002 2001 2000 

LG Electronics 32 32 30 30 29 32 28 26 20 

Fedders 12 12 14 14 22 21 22 20 22 

Electrolux (Frigidaire) 13 13 14 14 11 13 11 13 17 

Whirlpool 13 13 14 14 11 9 11 12 12 

Haier 8 8 6 5 6 9 12 11 6 

Samsung 5 5 5 5 6 5 2 1 3 

Sharp 4 4 5 4 4 3 4 3 2 

Friedrich 4 4 4 4 2 2 3 3 3 

UTC/Carrier 3 3 3 0 0 2 2 3 2 

Matsushita 2 2 1 2 2 3 2 2 3 

Others 4 4 4 8 7 5 3 6 10 

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Since 2007 there have been significant changes to the market. Fedders and Whirlpool left 

the market in 2008, and the status of other manufacturers including Sharp and Matsushita is 

unclear. Also not reflected in the market share data is the distinction between brand share and 

manufacturer share. GE and Midea, for example, are active brands that are not listed in the 

Appliance Magazine data, while some of the brands listed do not currently manufacture their 

room air conditioners. The manufacture of room air conditioners has, in recent years, entirely 

moved offshore. There is some limited manufacturing still occurring in North America, but most 

of the production is currently in Asia, primarily in China. 

3.6.2 Mergers and Acquisitions 

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

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

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

According to the September 2009 issue of Appliance Magazine, four manufacturers 

comprise 85 percent of the core appliance market share. “Core appliances” include dishwashers, 

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

manufacturers, and Figure 3.6.4 illustrates the breakdown of 2008 market shares in the core 

appliance category. 

Table 3.6.6 Core Appliance Manufacturers 

Core Appliance Manufacturers 

Whirlpool 

GE 

Electrolux (Frigidaire) 

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Figure 3.6.4 2008 Core Appliance Market Shares8 

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

based in Newton, Iowa, announced plans to merge in a deal worth $2.7 billion. 9

 Maytag 

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

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

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

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

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

extended the review to March 30, 2006. 

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

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

dishwasher market.10 Whirlpool claimed that their large potential residential laundry market 

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

under their Kenmore in-house brand. Whirlpool went on to say that they must periodically bid 

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

Kenmore units.11 

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

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

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

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

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

and desire to continue to operate that business.”12 

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

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

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

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

likely to harm consumer welfare.”13 

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

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

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

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

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

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

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

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

substantiated large cost savings and other efficiencies that would benefit consumers. 14 

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

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

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

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

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

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

(and therefore Frigidaire) in 1986. 

3.6.3 Small Business Impacts 

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

energy conservation standards for residential clothes dryers and room air conditioners. The Small 

Business Association (SBA) considers an entity to be a small business if, together with its 

affiliates, it employs less than a threshold number of workers specified in 13 CFR part 121, 

which relies on size standards and codes established by the North American Industry 

Classification System (NAICS). The threshold number for NAICS classification for 335224, 

which applies to household laundry equipment manufacturers and includes clothes dryer 

manufacturers, is 1,000 employees. The threshold number for NAICS classification for 333415, 

which applies to air conditioning and warm air heating equipment and commercial and industrial 

refrigeration equipment manufacturers and includes room air conditioner manufacturers, is 750 

employees. Searches of the SBA websitei

 to identify manufacturers within these NAICS codes 

i

 A searchable database of certified small businesses is available online at: 

http://dsbs.sba.gov/dsbs/search/dsp_dsbs.cfm. 

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that manufacture clothes dryers and/or room air conditioners revealed only Staber Industries, Inc. 

(Staber) of Groveport, Ohio, as a producer of laundry equipment. However, DOE notes that the 

Staber website indicates that their clothes dryer is manufactured by Whirlpool and rebranded. 

Therefore, DOE believes that there are no clothes dryer manufacturers that are considered a 

small business. Further, DOE is not aware of any room air conditioner manufacturers that are 

considered a small business. For any small business manufacturers of the two appliance 

products that DOE identifies, DOE will study the potential impacts on the small businesses in 

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

the NOPR analysis. 

3.6.4 Distribution Channels 

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

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

channels for residential clothes dryers and room air conditioners from publicly available sources. 

This section contains distribution channel information for residential appliances. 

For residential appliances, including room air conditioners and clothes dryers, the 

majority of consumers purchase their appliances directly from retailers. Table 3.6.7 identifies the 

types of retail stores through which major appliances, including residential clothes washers, are 

sold, based on data from the AHAM Fact Book 2005.15 

Table 3.6.7 Major Appliance Sales by Channel (Purchased between 2001 and 2005)16 

Type of Store Percentage of Appliance Purchases (%) 

Department Store (such as Sears or Kohls) 34.7 

Appliance Store or Consumer Electronics Store 30.9 

Home Improvement Store (such as Lowe’s or Home Depot) 23.8 

Discount Store (such as Wal-Mart or K-Mart) 2.0 

Membership Warehouse Club/Store (such as Sam’s or Costco) 1.8 

Another type of store 6.8 

Home appliance retailers generally obtain products directly from manufacturers. The 

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

the manufacturer directly to a retailer.17 A 2000 Consortium for Energy Efficiency (CEE) report 

determined that 5–10 percent of major appliance sales were made to commercial consumers such 

as builders, contractors, government sales, and property managers through 

distributors/wholesalers.18 

3.7 REGULATORY PROGRAMS 

The following section details current regulatory programs mandating energy conservation 

standards for residential clothes dryers and room air conditioners. Section 3.7.1 discusses current 

Federal energy conservation standards, while section 3.7.2 discusses the requirements of EISA 

2007 and section 3.7.3 provides an overview of existing State standards. In addition, section 

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3.7.4 reviews standards in Canada that may impact the companies servicing the North American 

market. 

3.7.1 Current Federal Energy Conservation Standards 

Current Federal energy conservation standards exist for residential clothes dryers. 

NAECA amended EPCA to establish prescriptive standards for clothes dryers, requiring that gas 

dryers manufactured on or after January 1, 1988 not be equipped with a constant burning pilot 

and further requiring that DOE conduct two cycles of rulemakings to determine if more stringent 

standards are justified. (42 U.S.C. 6295 (g)(3) and (4)) On May 14, 1991, DOE published a final 

rule in the Federal Register (FR) establishing the first set of performance standards for 

residential clothes dryers (56 FR 22250); the new standards became effective on May 14, 1994. 

(10 CFR 430.32(h)) Table 3.7.1 presents these standards for residential clothes dryers, expressed 

as EF in terms of pounds (lb) of clothes washed per kilowatt-hour (kWh). DOE initiated a second 

standards rulemaking for residential clothes dryers by publishing an advance notice of proposed 

rulemaking (ANOPR) in the Federal Register on November 14, 1994 (hereafter “November 

1994 ANOPR). 59 FR 56423. However, pursuant to the priority-setting process outlined in its 

Procedures for Consideration of New or Revised Energy Conservation Standards for Consumer 

Products (the “Process Rule”) (61 FR 36974 (July 15, 1996); establishing 10 CFR part 430, 

subpart C, appendix A), DOE classified the standards rulemaking for residential clothes dryers as 

a low priority for its fiscal year 1998 priority-setting process. As a result, DOE suspended the 

standards rulemaking activities for them. 

Table 3.7.1 Federal Energy Conservation Standards for Residential Clothes Dryers 

Clothes Dryer Classification Minimum EF

 (lb/kWh)) 

Electric, Standard (4.4 ft3 or greater capacity) 3.01 

Electric, Compact (120 V) (less than 4.4 ft3 capacity) 3.13 

Electric, Compact (240 V) (less than 4.4 ft3 capacity) 2.90 

Gas 2.67 

NAECA established performance standards for room air conditioners that became 

effective on January 1, 1990, and directed DOE to conduct two cycles of rulemakings to 

determine if more stringent standards are justified. (42 U.S.C. 6295 (c)(1) and (2)) On March 4, 

1994, DOE published in the Federal Register a NOPR for several products, including room air 

conditioners. 59 FR 10464. As a result of the Process Rule, DOE suspended activities to finalize 

standards for room air conditioners. DOE subsequently resumed rulemaking activities related to 

room air conditioners, and, on September 24, 1997, DOE published a final rule establishing an 

updated set of performance standards, with an effective date of October 1, 2000. (62 FR 50122; 

10 CFR 40.32(b)). Table 3.7.2 presents these standards for room air conditioners in terms of 

energy efficiency ratio (EER), which is expressed as cooling capacity in Btu/h per watt (W) of 

input power. 

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Table 3.7.2 Federal Energy Conservation Standards for Room Air Conditioners 

Room Air Conditioner Classification 

Minimum EER (Btu/h-W), 

effective as of 

Jan. 1, 1990 Oct. 1, 2000 

1. Without reverse cycle, with LS, and less than 6,000 Btu/h 8.0 9.7 

2. Without reverse cycle, with LS and 6,000 to 7,999 Btu/h 8.5 9.7 

3. Without reverse cycle, with LS and 8,000 to 13,999 Btu/h 9.0 9.8 

4. Without reverse cycle, with LS and 14,000 to 19,999 Btu/h 8.8 9.7 

5. Without reverse cycle, with LS and 20,000 Btu/h or more 8.2 8.5 

6. Without reverse cycle, without LS, and less than 6,000 Btu/h 8.0 9.0 

7. Without reverse cycle, without LS and 6,000 to 7,999 Btu/h 8.5 9.0 

8. Without reverse cycle, without LS and 8,000 to 13,999 Btu/h 8.5 8.5 

9. Without reverse cycle, without LS and 14,000 to 19,999 Btu/h 8.5 8.5 

10. Without reverse cycle, without LS and 20,000 Btu/h or more 8.2 8.5 

11. With reverse cycle, with LS, and less than 20,000 Btu/h 8.5 9.0 

12. With reverse cycle, without LS, and less than 14,000 Btu/h 8.0 8.5 

13. With reverse cycle, with LS, and 20,000 Btu/h or more 8.5 8.5 

14. With reverse cycle, without LS, and 14,000 Btu/h or more 8.0 8.0 

15. Casement-Only * 8.7 

16. Casement-Slider * 9.5 

* Casement-only and casement-slider room air conditioners were not separate product classes under standards 

effective January 1, 1990. These units were subject to the applicable standards in classes 1 through 14 based on unit 

capacity and the presence or absence of louvered sides and a reverse cycle. 

3.7.2 Energy Independence and Security Act of 2007 

There is currently no prescriptive Federal energy conservation standard for standby 

power consumption for either residential clothes washers or room air conditioners, nor is standby 

power incorporated into the efficiency metric prescribed by the existing DOE test procedure for 

either product. On December 19, 2007, the President signed into law EISA 2007, which contains 

numerous amendments to EPCA. Section 310 of EISA 2007 amends Section 325 of EPCA to 

require any final rule establishing or revising a standard for a covered product, adopted after July 

10, 2010, to incorporate standby mode and off mode energy use into a single amended or new 

standard. (42 U.S.C. 6295(gg)(3)(A)) If not feasible, the Secretary shall prescribe within the final 

rule a separate standard for standby mode and off mode energy consumption, if justified. (42 

U.S.C. 6295(gg)(3)(B)) 

Off mode is defined by EISA 2007 as “the condition in which an energy-using product – 

(I) is connected to a main power source; and (II) is not providing any standby or active mode 

function.” (42 U.S.C. 6295(gg)(1)(A)(ii)) Active mode refers to the one or more main functions, 

while standby is defined by EISA 2007 as “the condition in which an energy-using product (I) is 

connected to a main power source; and (II) offers 1 or more of the following user-oriented or 

protective functions: (aa) To facilitate the activation or deactivation of other functions (including 

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

Continuous functions, including information or status displays (including clocks) or sensor-based 

functions.” (Id.; 42 U.S.C. 6295(gg)(1)(A)(iii)) 

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The final rule for this rulemaking was scheduled to be published in the Federal Register 

by June 30, 2011. Thus, according to EISA 2007, energy conservation standards for residential 

clothes dryers and room air conditioners that would be put forth from this rulemaking are 

required to incorporate standby mode and off mode energy consumption. 

As noted above in section 0, the test procedure rulemaking to incorporate standby mode 

and off mode energy consumption in the energy descriptors for residential clothes dryers and 

room air conditioners was initiated in parallel with the current rulemaking. For both clothes 

dryers and room air conditioners, DOE has determined that it is technically feasible to 

incorporate standby mode and off mode energy consumption into overall energy consumption. 

Therefore, DOE adopted in the January 2011 TP Final Rule amendments which integrate standby 

mode and off mode energy use with the existing energy use metrics, creating new overall energy 

use descriptors, CEF and CEER for clothes dryers and room air conditioners, respectively. 76 FR 

972, 991–992 (Jan. 6, 2011). Accordingly, DOE is adopting the amended energy conservation 

standards for residential clothes dryers and room air conditioners based on these integrated 

metrics. 

3.7.3 State Energy Conservation Standards 

For those States which currently regulate residential clothes dryers and/or room air 

conditioners, no State energy conservation standards differ from Federal standards. 

3.7.4 Canadian Energy Conservation Standards 

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

energy conservation standards for residential clothes dryers and room air conditioners. 

Canadian Regulations stipulate minimum efficiency levels and definitions for electric 

residential clothes dryers which are identical to current U.S. Federal standards, mandating an EF 

of at least 3.01 for standard clothes dryers, an EF of at least 3.13 for compact (120 V) clothes 

dryers, and an EF of at least 2.90 for compact (240 V) clothes dryers. There are no Canadian 

Regulations covering gas clothes dryers.

 For room air conditioners, Canada’s Regulations are currently identical to U.S. Federal 

standards for all product classes. Canada’s Regulations, however, provide a stipulation in the 

definition of covered products that limits cooling capacity to 36,000 Btu/h. U.S. Federal 

standards do not specify a maximum cooling capacity. 

Canada has proposed increasing the required efficiency levels of room air conditioners, 

with an effective date of January 1, 2011. For many of the product classes, the proposed 

standards are the same as the current ENERGY STAR efficiency levels, which are roughly 10 

percent higher than the minimum standard levels. The current and proposed efficiency levels are 

summarized in Table 3.7.3 below. The proposal also calls for measurement and reporting of 

3-26 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

standby and off mode energy use, anticipating future regulation of the energy use of these 

modes. 

Table 3.7.3: Canada’s Proposed Efficiency Requirements for Room Air Conditioners 

Room Air Conditioner Classification 

Minimum EER (Btu/h-W) 

Current 

Standard 

Proposed 

1. Without reverse cycle, with LS, and less than 6,000 Btu/h 9.7 10.7 

2. Without reverse cycle, with LS and 6,000 to 7,999 Btu/h 9.7 10.7 

3. Without reverse cycle, with LS and 8,000 to 13,999 Btu/h 9.8 10.8 

4. Without reverse cycle, with LS and 14,000 to 19,999 Btu/h 9.7 10.7 

5. Without reverse cycle, with LS and 20,000 Btu/h or more 8.5 9.4 

6. Without reverse cycle, without LS, and less than 6,000 Btu/h 9.0 9.9 

7. Without reverse cycle, without LS and 6,000 to 7,999 Btu/h 9.0 9.9 

8. Without reverse cycle, without LS and 8,000 to 13,999 Btu/h 8.5 9.4 

9. Without reverse cycle, without LS and 14,000 to 19,999 Btu/h 8.5 9.4 

10. Without reverse cycle, without LS and 20,000 Btu/h or more 8.5 8.5 

11. With reverse cycle, with LS, and less than 20,000 Btu/h 9.0 9.9 

12. With reverse cycle, without LS, and less than 14,000 Btu/h 8.5 9.2 

13. With reverse cycle, with LS, and 20,000 Btu/h or more 8.5 9.5 

14. With reverse cycle, without LS, and 14,000 Btu/h or more 8.0 8.8 

15. Casement-Only 8.7 9.5 

16. Casement-Slider 9.5 9.5 

3.7.5 International Standby Power Regulatory Programs 

The International Energy Agency (IEA) has raised awareness of standby power through 

publications, international conferences, and policy advice to governments. In 1999, the IEA 

developed the “1-Watt Plan,” which proposed reducing standby power internationally in 

electronic devices and which advocates that all countries harmonize energy policies and adopt 

the same definition and test procedure. The IEA has advocated a 1 W requirement for all 

consumer electrical products (unless specifically excluded) in standby mode. The IEA also stated 

that IEC Standard 62301 provides an internationally sanctioned definition and test procedure for 

standby power which is now widely specified and used.j 

Australia has announced plans to implement a mandatory horizontal 1 W requirement for 

all consumer electrical products by 2012, including room air conditioners and clothes dryers. 19 

The European Union (EU) enacted the Commission Regulation (EC) No. 1275/2008 of 

December 17, 2008, implementing design requirements for standby and off mode power for 

electrical and electronic household and office equipment, including clothes dryers. Annex II of 

the regulation specifies the following maximum power requirements: 

1. One year after this Regulation has come into force: 

j

 For more information visit http://www.iea.org/. 

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(a) Power consumption in ‘off mode’: 

Power consumption of equipment in any off-mode condition shall not exceed 

[1.00] W. 

(b) Power consumption in ‘standby mode(s)’: 

The power consumption of equipment in any condition providing only a 

reactivation function, or providing only a reactivation function and a mere 

indication of enabled reactivation function, shall not exceed [1.00] W. 

The power consumption of equipment in any condition providing only 

information or status display, or providing only a combination of reactivation 

function and information or status display, shall not exceed [2.00] W. 

(c) Availability of off mode and/or standby mode 

Equipment shall, except where this is inappropriate for the intended use, provide 

off mode and/or standby mode and/or another condition which does not exceed 

the applicable power consumption requirements for off mode and/or standby 

mode when the equipment is connected to the mains power source. 

2. Four years after this Regulation has come into force: 

(a) Power consumption in ‘off mode’: 

Power consumption of equipment in any off-mode condition shall not exceed 

[0.50] W. 

(b) Power consumption in ‘standby mode(s)’: 

The power consumption of equipment in any condition providing only a 

reactivation function, or providing only a reactivation function and a mere 

indication of enabled reactivation function, shall not exceed [0.50] W. 

The power consumption of equipment in any condition providing only 

information or status display, or providing only a combination of reactivation 

function and information or status display, shall not exceed [1.00] W. 

(c) Availability of off mode and/or standby mode 

Equipment shall, except where this is inappropriate for the intended use, provide 

off mode and/or standby mode and/or another condition which does not exceed 

the applicable power consumption requirements for off mode and/or standby 

mode when the equipment is connected to the mains power source. 

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(d) Power management 

When equipment is not providing the main function, or when other energy-using 

product(s) are not dependent on its functions, equipment shall, unless 

inappropriate for the intended use, offer a power management function, or a 

similar function, that switches equipment after the shortest possible period of time 

appropriate for the intended use of the equipment, automatically into: 

— standby mode, or 

— off mode, or 

—	 another condition which does not exceed the applicable power consumption 

requirements for off mode and/or standby mode when the equipment is 

connected to the mains power source. The power management function shall 

be activated before delivery. 

3.8 VOLUNTARY PROGRAMS 

DOE reviewed several voluntary programs promoting energy-efficient residential 

appliances in the United States. Many programs, including the CEE, ENERGY STAR, and the 

Federal Energy Management Program (FEMP), establish voluntary energy conservation 

standards for these products. 

3.8.1 Consortium for Energy Efficiency

 The CEEk develops initiatives for its North American members to promote the 

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

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

increased adoption of energy-efficient technologies. 

CEE issues voluntary specifications for room air conditioners. Qualifying units must 

use at least 15 percent less electricity, based on EER, than the Federal standard. Table 3.8.1 

presents the room air conditioner efficiency specifications, effective January 2003, under its 

Super-Efficient Home Appliance Initiative (SEHA). Unlike for Federal standards, no distinction 

is made among the features present on a qualifying unit (i.e., louvered sides, reverse cycle, etc.). 

The classes are differentiated only by cooling capacity. 

k

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

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Table 3.8.1 CEE Criteria for Room Air Conditioners 

Product Class (Btu/h) Tier 1 (EER, Btu/h-W) Tier 2 (EER, Btu/h-W) 

< 8,000 11.2 11.6 

8,000 to 13,999 11.3 11.8 

14,000 to 19,999 11.2 11.6 

≥ 20,000 9.8 10.2 

3.8.2 ENERGY STAR 

ENERGY STAR, a voluntary labeling program jointly administered by the U.S. 

Environmental Protection Agency (EPA) and DOE, identifies energy efficient products through a 

qualification processl

. To qualify, a product must exceed Federal minimum standards by a 

specified amount, or if no Federal standard exists, exhibit selected energy-saving features. The 

ENERGY STAR program works to recognize the top quartile of products on the market, 

meaning that approximately 25 percent of the models on the market at the time the qualifying 

criteria are specified meet or exceed the ENERGY STAR levels. ENERGY STAR specifications 

exist for several products, including room air conditioners. 

Prior to November, 2005, ENERGY STAR room air conditioner criteria existed for 

only cooling-only units; i.e., those without a reverse cycle or electric resistance heating. New 

criteria which became effective November 16, 2005 added ENERGY STAR specifications for 

room air conditioners with reverse cycle operation. The current ENERGY STAR criteria for 

room air conditioners are listed in Table 3.8.2. According to the ENERGY STAR program, 54 

percent of room air conditioners sold in 2006 were ENERGY STAR-qualified. 

l

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

3-30
 
 

 

 

 

 

 

 

Table 3.8.2 ENERGY STAR Criteria for Room Air Conditioners 

Without reverse cycle and with louvered sides Required EER 

(Btu/h-W) 

1. Less than 6,000 Btu/h ≥ 10.7 

2. 6,000 to 7,999 Btu/h ≥ 10.7 

3. 8,000 to 13,999 Btu/h ≥ 10.8 

4. 14,000 to 19,999 Btu/h ≥ 10.7 

5. 20,000 Btu/h or more ≥ 9.4 

Without reverse cycle and without louvered sides 

6. Less than 6,000 Btu/h ≥ 9.9 

7. 6,000 to 7,999 Btu/h ≥ 9.9 

8. 8,000 to 13,999 Btu/h ≥ 9.4 

9. 14,000 to 19,999 Btu/h ≥ 9.4 

10. 20,000 Btu/h or more ≥ 9.4 

With reverse cycle and with louvered sides 

11. Less than 20,000 Btu/h ≥ 9.9 

12. 20,000 Btu/h or more ≥ 9.4 

With reverse cycle and without louvered sides 

13. Less than 14,000 Btu/h ≥ 9.4 

14. 14,000 Btu/h or more ≥ 8.8 

Casement 

15. Casement-Only ≥ 9.6 

16. Casement-Slider ≥ 10.5 

3.8.3 Federal Energy Management Program 

DOE’s Federal Energy Management Programm (FEMP) works to reduce the cost and 

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

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

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

efficient equipment, including certain residential appliances. 

FEMP issues energy efficiency recommendations for room air conditioners. Table 3.8.3 

presents the room air conditioner recommendations. 

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

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Table 3.8.3 FEMP Recommendations for Room Air Conditioners 

Air Conditioner Type and Capacity Required EER (Btu/h-W) 

With louvered sides, < 20,000 Btu/h ≥ 10.7 

With louvered sides, ≥ 20,000 Btu/h ≥ 9.4 

Without louvered sides, < 8,000 Btu/h ≥ 9.9* 

Without louvered sides, ≥ 8,000 Btu/h ≥ 9.4 

* FEMP states that currently there are no models that can meet this recommendation, and 

suggests purchasing a unit with the best available EER. 

FEMP estimates that a typical household using a louvered-side model room air 

conditioner with a cooling capacity of 10,000 Btu/h and 750 operating hours per year with an 

EER of 9.8 (DOE minimum standard) can save $40 in energy costs over the lifetime of the unit 

(assuming Federal average energy prices) by upgrading to a unit with an EER of 10.7 (FEMP 

recommendation). The lifetime energy savings increase to $80 by purchasing a unit with an EER 

of 11.5. 

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

requires that Federal agencies purchase commercially available products with low standby 

power. In addition, Executive Order 13221 of July 31, 2001, directs Federal agencies, when 

purchasing a product that contains an internal standby power function or that uses an external 

standby power device, to purchase such a product that consumes no more than 1 W in standby 

power mode or, if such a product is not available, to select a product with the lowest available 

standby power consumption. These requirements shall apply only if the lower-wattage eligible 

product is lifecycle cost effective and practicable, and the utility and performance of the product 

is not compromised by the lower wattage requirement. 66 FR 40571. 

3.8.4 Rebates for Highly Energy-Efficient Products 

Electric utilities and other organizations promote the purchase of highly energy efficient 

residential clothes washers through consumer rebates. Typically, these programs offer rebates for 

products meeting existing ENERGY STAR efficiency levels. Table 3.8.4 lists some rebates that 

were offered in 2008. Some utilities also offer incentives to retire old and inefficient appliances. 

Table 3.8.4 Rebates Offered for Highly Energy Efficient Room Air Conditioners in 200820 

Utility/Organization* Rebate Level ($) 

Alliant Energy (Iowa and Minnesota) 50 (ENERGY STAR) 

Efficiency Vermont 25 (ENERGY STAR) 

40 (CEE Tier 1) 

Los Angeles Department of Water and Power (CA) 50 (ENERGY STAR) 

Pacific Gas and Electric Company (Northern California) 50 (ENERGY STAR) 

Sacramento Municipal Utility District (CA) 50 (ENERGY STAR) 

San Diego Gas & Electric (CA) 50 (ENERGY STAR) 

* The table includes a survey of a limited number of rebate programs. Additional programs may exist. 

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3.9 HISTORICAL SHIPMENTS 

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

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

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

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

shipments analysis (chapter 9 of this TSD). 

3.9.1 New Home Starts 

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

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

including residential clothes dryers, these products are also fixtures in many new homes. Room 

air conditioner shipments are not as greatly impacted by new home starts, as they are often 

purchased for use in existing construction. 

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

started in the United States from 1998–2009. Over the 5-year period from 2000–2005, singlefamily home starts increased 39.4 percent, to 1,716,000 units annually. However, between 2005 

and 2009, single-family home starts decreased 74.1 percent, to 445,100 units annually. Multifamily unit starts remained relatively flat between 1998 and 2005, hovering around 350,000 units 

annually. However, between 2005 and 2009, multi-family unit starts decreased by 69.1 percent, 

to around 108,900 units annually.21 

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

the United States from 1998–2009 22 

3.9.2 Unit Shipments 

AHAM submitted data for the annual unit shipments for residential clothes dryers, and 

DOE obtained additional shipments data from Appliance Magazine. Table 3.9.1 presents the 

annual shipments of clothes dryers for the 15-year period from 1993 to 2008. The shipments of 

electric clothes dryers increased 73 percent from 1993 to 2006, to about 6.4 million units in 

2006. However, between 2006 and 2008, shipments of electric clothes dryers decreased by 11.6 

percent, to 5.6 million units in 2008. The shipments of gas dryers increased 40 percent from 

1993 to 2006, to about 1.6 million units in 2006. Again, between 2006 and 2008, shipments of 

gas clothes dryers decreased by about 16 percent, to about 1.4 million in 2008. 

3-34 

 

 

 

 

Table 3.9.1 Industry Shipments of Residential Clothes Dryers (Domestic and Import, in 

Thousands of Units)23 

Year 

Clothes Dryers (Thousands) 

Electric Standard 

Electric 

Compact 

Electric Gas Total 

2008** 5,620 1,353 6,973 

2007** 6,035 1,530 7,565 

2006 6,360 6,246 114 1,614 7,974 

2005 6,408 6,330 78 1,707 8,115 

2004 6,262 6,159 103 1,660 7,922 

2003 5,718 5,622 96 1,616 7,334 

2002 5,402 1,490 6,892 

2001 5,117 1,384 6,501 

2000 5,095 1,480 6,575 

1999 4,865 1,444 6,309 

1998 4,482 1,307 5,789 

1997 4,115 1,195 5,310 

1996 3,947 1,193 5,140 

1995 3,823 1,169 4,992 

1994 3,838 1,239 5,077 

1993 3,674 1,156 4,830 

*AHAM did not provide data for standard and compact electric clothes dryers prior to 2003, nor any clothes dryer
 

shipments data for 2007 and 2008.
 

**Source: September 2008 and 2009 Appliance Magazine “Share-of-Market Picture”.
 

AHAM’s Fact Book 2003 and 2005, as well as Appliance Magazine, provide annual unit 

shipments for room air conditioners. Table 3.9.2 presents the annual shipments of room air 

conditioners for the 14-year period from 1994 to 2008. Shipments of room air conditioners 

increased sharply in 1999 and again in 2003 and 2006. 

Table 3.9.2 Industry Shipments of Room Air Conditioners (Domestic and Import, in 

Thousands of Units) 24 

Year Room Air Conditioners 

(Thousands) 

2008* 9,086 

2007* 9,550 

2006* 10,055 

2005 8,032 

2004 8,082 

2003 8,216 

2002 6,153 

2001 5,575 

2000 6,496 

1999 6,114 

1998 4,403 

1997 4,123 

1996 4,825 

1995 4,300 

1994 3,853 

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*Shipments data for 2006 through 2008 were obtained from the September 2007-2009 Appliance Magazine “Shareof-Market Picture”. 

ENERGY STAR market share data are an indicator of the demand for energy efficient 

products. Table 3.9.3 shows the ENERGY STAR-qualified room air conditioner shipments and 

market share from 1997 to 2006 provided in the ENERGY STAR Room Air Conditioner 2007 

Product Snapshot. Sales of ENERGY STAR qualified room air conditioners have grown faster 

than the overall total sales of clothes washers over the 10-year period, with market share 

increasing more than 40 percent. 

Table 3.9.3 ENERGY STAR Shipments for Room Air Conditioners (Domestic and Import) 

Year 

Shipments % ENERGY 

STAR of 

Total

ENERGY STAR- 25

Qualified Other Total26 

2006 5,429,862 4,625,438 10,055,300* 54 

2005 4,176,640 3,855,360 8,032,000 52 

2004 2,828,700 5,253,300 8,082,000 35 

2003 2,382,640 5,833,360 8,216,000 29 

2002 2,215,080 3,937,920 6,153,000 36 

2001 669,000 4,906,000 5,575,000 12 

2000 1,234,240 5,261,760 6,496,000 19 

1999 794,820 5,319,180 6,114,000 13 

1998 572,390 3,830,610 4,403,000 13 

1997 494,760 3,628,240 4,123,000 12 

*Total shipments data for 2006 from the September 2007 Appliance Magazine “Share-of-Market Picture for 2006”. 

3.9.3 Value of Shipments 

Table 3.9.4 provides the value of household laundry equipment shipments, which 

includes residential clothes dryer and clothes washer shipments, from 1994 to 2008 based upon 

data from the U.S. Census Bureau’s Annual Survey of Manufacturers (ASM)n

. The ASM 

expresses all dollar values in nominal dollars; i.e., 2008 data are expressed in 2008 dollars, and 

2005 data are expressed in 2005 dollars. Using the Gross Domestic Product Implicit Price 

Deflator, DOE converted each year’s value of shipments to 2008 dollars. In constant dollars, the 

value of household laundry shipments increased 14 percent from 1994 to 2005, but then 

decreased 25 percent between 2005 and 2008. During the same period, unit shipments of 

residential clothes dryers increased about 37 percent, suggesting that the U.S. laundry appliance 

industry is very competitive. 

n

 Available online at www.census.gov/manufacturing/asm/index.html. 

3-36 

 

 

 

 

 

 

 

 

Table 3.9.4 Household Laundry Equipment Value of Shipments by Year27 

Year Value of Shipments in Nominal 

Dollars ($ million) 

Value of Shipments in 2008 

Dollars ($ million) 

2008 4,232 4,232 

2007 4,678 4,780 

2006 5,129 5,395 

2005 5,222 5,672 

2004 4,987 5,598 

2003 4,658 5,377 

2002 4,352 5,132 

2001 4,549 5,451 

2000 4,420 5,416 

1999 4,365 5,464 

1998 4,249 5,397 

1997 3,710 4,766 

1996 3,699 4,836 

1995 3,541 4,717 

1994 3,671 4,992 

Table 3.9.5 provides the value of shipments for the NAICS product class which includes 

room air conditioners and dehumidifiers, other than portable dehumidifiers (NAICS product 

class code 3334156). The value of shipments for these products has decreased 72 percent from 

1994 to 2008 while unit shipments of room air conditioners have increased about 136 percent 

during the same time period, indicating significant industry competition. 

Table 3.9.5 “Room Air-Conditioners and Dehumidifiers, Except Portable Dehumidifiers” 

Product Class Value of Shipments by Year28 

Year Value of Shipments in Nominal 

Dollars ($ million) 

Value of Shipments in 2008 

Dollars ($ million) 

2008 452 452 

2007 646 660 

2006 542 570 

2005 572 621 

2004 598 671 

2003 820 947 

2002 839 989 

2001 944 1,131 

2000 984 1,206 

1999 1,177 1,473 

1998 1,034 1,313 

1997 979 1,258 

1996 1,367 1,787 

1995 1,300 1,732 

1994 1,183 1,609 

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

being used after consumers purchase new units of same product. Table 3.9.6 presents the various 

methods by which consumers dispose of their older appliances. 

Table 3.9.6 Disposition of Previous Appliance (Percentage)29 

Product 

Kept It 

(%) 

Left with 

Previous 

Home (%) 

Sold / Gave 

Away (%) 

Recycling 

Facility (%) 

Left at 

Curb for 

Disposal 

(%) 

Retailer 

Took Away 

(%) 

Clothes Dryers 5 19 25 18 10 23 

Room Air Conditioners 16 21 40 9 9 4 

3.9.4 Imports and Exports 

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

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

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

imports decreased 9.7 percent in 2009 as compared to 2008. Major appliance unit exports 

decreased 17.5 percent over the same period.

 Table 3.9.7 shows selected import data from AHAM’s Import/Export Trade Report – 

December 2009.30 For non-coin-operated clothes dryers with a capacity less than 10 kilograms 

(kg) (i.e., residential clothes dryers), the number of units imported decreased by 19.4 percent 

from 2008 to 2009, while the value of units imported decreased by 13.7 percent over that same 

period. For room air conditioners with a capacity less than 2.93 kW (10,000 Btu/h), both the 

number and value of units imported decreased by more than 18 percent from 2008 to 2009. For 

room air conditioners with a capacity between 2.93 to 4.98 kW (10,000 to 17,000 Btu/h) both the 

number and value of units imported decreased by more than 7.5 percent. For room air 

conditioners with a capacity greater than 4.98 kW (17,000 Btu/h) both the number and value of 

units imported decreased by more than 27 percent 

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Table 3.9.7 2008-2009 Imports of Appliances Covered by this Rulemaking31 

Appliance Description 

Jan. – Dec. 

2009 

Jan. – Dec. 

2008 % Change 

Jan. – Dec. 

2009 

Jan. – Dec. 

2008 % Change 

Units $ Mil (Nominal) 

Drying machines, except 

coin-operated, capacity ≤ 

10 kg 

935,249 1,159,852 -19.4 209.598 242.892 -13.7 

Air conditioners, 

window/wall, capacity < 

2.93 kW 

(<10,000 Btu/h) 

3,869,851 4,965,619 -22.1 424.696 519.801 -18.3 

Air conditioners, 

window/wall, selfcontained, capacity 2.93­

4.98 kW 

(10,000 to 17,000 Btu/h) 

1,751,125 2,109,678 -17.0 349.816 378.262 -7.5 

Air conditioners, 

window/wall, selfcontained, capacity 

≥4.98 kW 

(≥17,000 Btu/h) 

432,145 636,289 -32.1 130.253 178.319 -27.0 

Table 3.9.8 shows selected export data from AHAM’s Import/Export Trade Report – 

December 2009.

32 For the 1-year period from 2008 to 2009, the number and value of unit exports 

of non-coin-operated clothes dryers and all room air conditioners decreased significantly. 

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Table 3.9.8 2007-2008 Exports of Appliances Covered by this Rulemaking33 

Appliance Description 

Jan. – Dec. 

2009 

Jan. – Dec. 

2008 % Change 

Jan. – Dec. 

2009 

Jan. – Dec. 

2008 % Change 

Units $ Mil (Nominal) 

Drying machines, except 

coin-operated, capacity ≤ 

10 kg 

129,186 158,492 -18.5 27.817 34.725 -19.9 

Air conditioners, 

window/wall, capacity < 

2.93 kW/h 

(<10,000 Btu/h) 

72,358 103,999 -30.4 23.662 33.536 -29.4 

Air conditioners, 

window/wall, selfcontained, capacity 2.93­

4.98 kW/h 

(10,000 to 17,000 Btu/h) 

48,483 73,737 -34.2 21.270 30.555 -30.4 

Air conditioners, 

window/wall, selfcontained, capacity 

≥4.98 kW/h 

(≥17,000 Btu/h) 

39,453 51.673 -23.6 26.915 36.386 -26.0 

3.10 HISTORICAL EFFICIENCIES 

Table 3.10.1 shows the historical efficiency trends and the percentage of domestic 

shipments by EER classification for room air conditioners from 1980 to 2004, as provided in 

the AHAM Fact Book 2005. New coil designs, increased motor and compressor efficiencies, and 

better air circulation systems have all contributed to the 11-percent efficiency increase from 1990 

through 2004. The percentage of domestic shipments by EER classification also shows a trend 

towards high efficiency room air conditioners. The increases in EER and percent of shipments of 

higher efficiency room air conditioners in 2000 and 2001 were a result of the new energy 

conservation standards which became effective in October 1, 2000. 

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Table 3.10.1 Room Air Conditioner Energy Efficiency and Consumption Trends (Shipment 

Weighted Averages)34 

Year EER (Btu/h) 

Percentage of Domestic Shipments (%) 

Less than 8.5 EER 8.5 - 9.4 EER 9.5 EER and Higher 

2004 9.71 0.04 11.2 88.8 

2003 9.75 0.03 9.0 91.0 

2002 9.75 0.02 12.4 87.6 

2001 9.63 0.1 13.8 86.0 

2000 9.3 14.2 34.2 51.5 

1999 9.07 26.9 41.4 31.7 

1998 

1997 9.09 16.7 47.3 36.0 

1996 9.08 16.0 49.3 34.7 

1995 9.03 19.3 51.9 28.8 

1994 8.97 24.1 50.9 25.0 

1993 9.05 24.8 55.3 19.9 

1992 8.88 24.6 58.1 17.3 

1991 8.8 27.5 57.2 15.3 

1990 8.73 28.9 58.3 12.8 

1980 7.02 88.6 9.3 2.1 

3.11 MARKET SATURATION 

AHAM’s Fact Book 2005 presents the market saturation for residential clothes dryers and 

room air conditioners. Table 3.11.1 presents the appliance saturation and percentage of U.S. 

households with each product as reported in the AHAM Fact Book 2005. The number of U.S. 

households with each product is based on U.S. Census Bureau projections of occupied units in 

the relevant year. The saturation of gas dryers as a percentage of households has remained 

constant since 2001, while the saturation of electric dryers has increased. Conversely, the 

saturation of room air conditioners as a percentage of households has decreased somewhat since 

1990. 

Table 3.11.1 Appliance Saturation (Number in Millions and Percentage of U.S. Households 

with Product) 35 

1970 1982 1990 2001 2005 

Product # % # % # % # % # % 

Dryers, Electric 18.6 29.3 42.3 50.6 56.1 60.1 61.8 59.3 67.6 62.1 

Dryers, Gas 7.8 12.3 12.3 14.7 19.1 20.5 19.8 19 20.7 19 

Room Air 

Conditioners 16.9 25 22.6 27 30.2 32.4 26.9 25.8 27.4 25.2 

3.12 PRODUCT RETAIL PRICES 

Table 3.12.1 presents the average retail prices of residential clothes dryers and room air 

conditioners for select years between 1980 and 2002. The retail prices presented in nominal 

3-41 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

dollars are obtained from the AHAM Fact Book 2003. To adjust these prices to constant 2002 

dollars, the values are scaled by the annual U.S. city average Consumer Price Index (CPI), 

published by the U.S. Department of Labor’s Bureau of Labor Statistics (BLS). Although retail 

prices in nominal dollars for electric and gas clothes dryers have increased since 1980, the 

increase has been at a slower rate than the CPI, so that in constant 2002 dollars the retail prices 

have decreased. Prices of room air conditioners in both nominal and 2002 dollars have 

decreased in the same time period. 

Table 3.12.1 Residential Appliance Retail Prices36 

Product 

Average Retail Prices 

(Nominal $) 

Average Retail Prices 

(2002$) 

1980 1994 2002 1980 1994 2002 

Electric Clothes Dryers 286 327 396 624 397 396 

Gas Clothes Dryers 315 325 467 688 395 467 

Room Air Conditioners 372 351 322 812 426 322 

DOE used the consolidated room air conditioner database developed for the energy 

efficiency analysis in section 3.15.3.2 to produce a more recent overview of the retail prices. The 

prices shown represent retail prices offered by a wide variety of retailers and internet 

distributors. The prices reflected information collected in August 2008. 

Figure 3.12.1 and Figure 3.12.2 show the retail price versus cooling capacity of each 

room air conditioner listed in the databases, shown separately for product class groups 1-5 and 

6-10. There is a definite positive trend in cost for both of the graphs, however, the range of prices 

at a given capacity is much wider for product classes 1 through 5. The second graph shows that 

there are a limited number of products in the product class 6 through 10 group with capacities 

higher than 15,000 Btu/h. This represents primarily product classes 9 and 10. 

3-42 

$­

$200 

$400 

$600 

$800 

$1,000 

$1,200 

$1,400 

$1,600 

0 5 10 15 20 25 30 35 

Retail Price ($) 

Room Air Conditioner Capacity (kBtu/h) 

Figure 3.12.1 Retail Prices for Room Air Conditioners, Product Classes 1 through 5 

3-43 

 

 

 

 

 

 

 

$­

$200 

$400 

$600 

$800 

$1,000 

$1,200 

$1,400 

$1,600 

0 5 10 15 20 25 30 

Retail Price ($) 

Room Air Conditioner Capacity (kBtu/h) 

Figure 3.12.2 Retail Prices for Room Air Conditioners, Product Classes 6 through 10 

Figure 3.12.3 through Figure 3.12.8 show the retail price as a function of EER for the 

room air conditioners in the consolidated database, specifically for the product classes analyzed 

in detail in the engineering analysis (product classes 1, 3, 5, and 8). The figures show 

concentrations of products at the baseline and ENERGY STAR efficiency levels. Figure 3.12.3 

shows an approximate $50 price increment for those units in product class 1 with an ENERGY 

STAR rating. However, there are not strong trends of price as a function of EER observed for 

product classes 3, 5, and 8. 

3-44 

Figure 3.12.3 Retail Price versus EER for Product Class 1 

3-45 

Figure 3.12.4 Retail Price versus EER for Product Class 2 

3-46 

Figure 3.12.5 Retail Price versus EER for Product Class 3 

3-47 

Figure 3.12.6 Retail Price versus EER for Product Class 4 

3-48 

Figure 3.12.7 Retail Price versus EER for Product Class 5 

3-49 

 

 

 

 

 

 

 

 

 

 

Figure 3.12.8 Retail Price versus EER for Product Class 8 

3.13 INDUSTRY COST STRUCTURE 

DOE developed the household appliance, household laundry, and air-conditioning and 

warm air heating and commercial/industrial refrigeration equipment industries cost structures 

from publicly available information from the ASM (Table 3.13.1 through Table 3.13.6) and from 

the Securities and Exchange Commission (SEC) 10-K reports filed by publicly owned 

manufacturers (summarized in Table 3.13.7). Table 3.13.1 presents the home appliance industry 

employment levels and earnings from 1994–2008. The statistics illustrate a steady decline in the 

number of production and non-production workers in the industry. 

Because the ASM expresses all dollar values in constant 2008 dollars, the following table 

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

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

for all employees. 

3-50 

 

 

 

 

 

 

 

 

 

 

Table 3.13.1 Household Appliance Industry Employment and Earnings 37 

Year 

Production Workers 

(‘000) 

All Employees 

(‘000) 

Payroll for All Employees 

(2008$ Mil) 

2008 49.1 57.5 2,296.0 

2007 56.2 65.5 2,537.9 

2006 60.0 69.7 2,777.8 

2005 64.3 76.9 2,928.2 

2004 69.4 83.7 3,244.1 

2003 71.0 85.3 3,326.1 

2002 73.5 88.8 3,525.2 

2001 76.6 92.6 3.693.5 

2000 82.7 99.5 4,023.4 

1999 82.3 97.9 3,892.2 

1998 82.4 99.5 3,919.5 

1997 79.8 97.2 3,742.3 

1996 87.1 108.1 4,010.7 

1995 88.9 110.8 4,077.0 

1994 90.4 110.4 4,063.1 

Table 3.13.2 presents the employments levels and earnings for just the household laundry 

portion of the appliance industry from 1994-2007o

. Statistics for both employment levels and 

payroll show a steady fluctuation over the past 14 years, with payroll and employment levels 

again showing a positive correlation. 

Table 3.13.2 Household Laundry Industry Employment and Earnings 38 

Year 

Production Workers 

(‘000) 

All Employees 

(‘000) 

Payroll for All Employees 

(2007$ Mil) 

2007 10.3 11.1 415.1 

2006 12.4 14.1 587.8 

2005 12.6 14.5 549.2 

2004 12.9 15.1 606.9 

2003 13.1 15.5 645.8 

2002 13.5 15.9 711.8 

2001 12.8 14.9 633.9 

2000 13.3 15.5 681.6 

1999 14.0 15.9 678.3 

1998 14.3 16.7 702.0 

1997 12.9 14.8 603.0 

1996 12.9 15.7 640.4 

1995 12.9 16.3 678.7 

1994 12.9 16.2 714.4 

Table 3.13.3 shows the employment levels and payroll for the air conditioning and warm 

air heating and commercial/industrial refrigeration equipment industry. Industry statistics show a 

steady decrease in the levels of employment and payroll, and the same correlation between these 

parameters as seen in the appliance industry. 

o

 Data for 2008 was withheld from the U.S. Census Bureau ASM to avoid disclosing data for individual companies. 

3-51 

 

 

 

 

 

 

 

 

 

Table 3.13.3 Air-Conditioning & Warm Air Heating & Commercial/Industrial 

Refrigeration Equipment Industry Employment and Earnings 39 

Year 

Production Workers 

(‘000) 

All Employees 

(‘000) 

Payroll for All Employees 

(2008$ Mil) 

2008 70.8 96.5 4,010.0 

2007 74.7 101.5 4,120.2 

2006 74.9 98.1 4,224.6 

2005 75.9 102.2 4,271.7 

2004 73.1 99.0 4,137.8 

2003 77.5 104.7 4,353.6 

2002 80.4 108.3 4,493.6 

2001 89.0 118.9 4,727.6 

2000 98.0 127.4 5,222.9 

1999 95.9 124.0 5,054.9 

1998 92.0 120.0 4,877.5 

1997 91.0 119.4 4,720.1 

1996 104.0 134.9 5,849.8 

1995 103.2 134.8 5,723.0 

1994 99.1 130.6 5,572.9 

Table 3.13.4 presents the costs of materials and industry payroll as a percentage of value 

of shipments from 1994–2008. The cost of materials as a percentage of value of shipments has 

fluctuated slightly over the 15-year period. DOE notes that fluctuations in raw material costs are 

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

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

of shipments has declined since 2000. 

Table 3.13.4 Household Appliance Industry Census Data40 

Year 

Cost of Materials as a 

Percentage of Value of 

Shipments (%) 

Cost of Payroll for 

Production Workers as a 

Percentage of Value of 

Shipments (%) 

Cost of Total Payroll 

(Production + Admin.) as a 

Percentage of Value of 

Shipments (%) 

2008 58.5 7.7 10.5 

2007 57.8 8.0 10.5 

2006 57.9 8.4 10.9 

2005 56.9 8.3 11.0 

2004 57.2 9.0 12.1 

2003 55.9 9.2 12.5 

2002 54.9 9.7 13.4 

2001 56.8 10.1 13.8 

2000 55.8 10.2 14.0 

1999 54.7 10.2 13.9 

1998 56.0 10.0 13.7 

1997 52.8 9.9 13.6 

1996 56.8 9.9 13.9 

1995 57.7 9.4 13.7 

1994 55.5 9.2 13.1 

3-52 

 

 

 

 

 

 

 

 

 

Table 3.13.5 shows the cost of materials and industry payroll as a percentage of value of 

shipments for the household laundry industry from 1994-2007p

. DOE observed a decline in both 

the cost of materials and payroll as a percentage of value of shipments from 1996–2005. 

However, from 2005-2007, the cost of materials and payroll for production workers as a 

percentage of value of shipments has increased. Table 3.13.6 shows the trends for the air 

conditioning and warm air heating and commercial/industrial refrigeration equipment industry, 

which showed decreases in percentages of both cost of material and payroll from 1996-2005. 

However, from 2005-2008, the cost of materials as a percentage of value of shipments has 

increased, whereas the cost of payroll as a percentage of value of shipments has remained 

relatively constant. 

p

 Data for 2008 was withheld from the U.S. Census Bureau ASM to avoid disclosing data for individual companies. 

3-53 

 

 

 

 

Table 3.13.5 Household Laundry Industry Census Data 41 

Year 

Cost of Materials as a 

Percentage of Value of

Shipments (%) 

Cost of Payroll for 

Production Workers as a 

Percentage of Value of

Shipments (%) 

Cost of Total Payroll 

(Production + Admin.) as a 

Percentage of Value of

Shipments (%) 

2007 60.1 8.2 9.4 

2006 61.2 9.0 11.1 

2005 52.5 7.8 9.9 

2004 52.5 8.5 11.1 

2003 56.0 9.4 12.3 

2002 56.6 10.4 14.2 

2001 56.2 9.2 11.9 

2000 54.2 9.7 12.9 

1999 51.4 10.0 12.7 

1998 54.5 10.3 13.3 

1997 56.1 10.6 12.9 

1996 64.4 10.6 13.5 

1995 62.3 10.5 14.7 

1994 63.4 10.4 14.6 

Table 3.13.6 Air Conditioning & Warm Air Heating & Commercial/Industrial 

Refrigeration Equipment Industry Census Data42 

Year 

Cost of Materials as a 

Percentage of Value of 

Shipments (%) 

Cost of Payroll for 

Production Workers as a 

Percentage of Value of 

Shipments (%) 

Cost of Total Payroll 

(Production + Admin.) as a 

Percentage of Value of 

Shipments (%) 

2008 56.7 8.4 13.9 

2007 57.7 8.5 13.9 

2006 53.2 8.9 13.8 

2005 55.3 8.7 14.1 

2004 53.3 9.2 14.8 

2003 52.5 9.9 16.0 

2002 51.3 10.2 16.5 

2001 54.8 10.3 16.5 

2000 56.3 10.7 17.0 

1999 55.9 10.2 16.1 

1998 58.1 10.5 16.3 

1997 56.7 10.6 16.8 

1996 62.0 12.0 17.6 

1995 62.7 12.3 18.1 

1994 59.5 12.4 18.3 

Table 3.13.7 presents the industry cost structure derived from SEC 10-K reports of 

publicly-owned home appliance manufacturers which produce residential clothes dryers and 

room air conditioners. DOE averaged the financial data from 2002–2007 of several companies to 

obtain an industry average. Each financial statement entry is presented as a percentage of total 

revenues. 

3-54 

 

 

 

 

Table 3.13.7 Industry Cost Structure Using SEC Data 

Financial Statement Entry Percent of Revenues 

(%) 

Cost of sales 81.3 

Net income 1.7 

Selling, general and administrative 12.8 

Capital expenditure 3.3 

Research and development 2.3 

Depreciation and amortization 3.3 

Net plant, property and equipment 18.7 

Working capital 1.6 

Figure 3.13.1 presents the industry-average gross margin over the period from 2002– 

2007 for the same manufacturers from which the industry cost structure is derived. The slope of 

the curve indicates the downward cost pressure facing manufacturers. 

2002 2003 2004 2005 2006 2007 

Figure 3.13.1 Industry Gross Margin Derived from SEC Data 

0.0% 

5.0% 

10.0% 

15.0% 

20.0% 

25.0% 

Industry Average Gross Margin 

3-55 

 

 

 

 

 

 

 

 

3.14 INVENTORY LEVELS AND CAPACITY UTILIZATION RATES 

Table 3.14.1 through Table 3.14.3 shows the year-end inventory for the household 

appliance, household laundry, and air conditioning and warm air heating and 

commercial/industrial refrigeration equipment industries, according to the ASM. Both in dollars 

and as a percentage of value of shipments, the end-of-year inventory for these industries has 

steadily declined since 1995. This data illustrates that domestic manufacturers are retaining less 

of their inventories each consecutive year. 

Table 3.14.1 Household Appliance Industry Census Data43 

Year 

End-of-Year Inventory 

(2008$ Mil) 

End-of-Year Inventory as a 

Percentage of Value 

of Shipments (%) 

2008 1,918.2 8.7 

2007 2,040.0 8.4 

2006 1,774.0 7.0 

2005 1,772.0 6.6 

2004 1,959.3 7.3 

2003 1,964.0 7.4 

2002 2,111.8 8.1 

2001 2,347.6 8.8 

2000 2,649.0 9.2 

1999 2,639.6 9.4 

1998 2,845.9 10.0 

1997 2,735.3 10.0 

1996 3,001.8 10.4 

1995 3,315.5 11.1 

1994 3,436.4 11.1 

3-56
 
 

 

 

 

 

 

 

 

 

Table 3.14.2 Household Laundry Industry Census Data44 

Year 

End-of-Year Inventory 

(2007$ Mil) 

End-of-Year Inventory as a 

Percentage of Value 

of Shipments (%) 

2007 258.4 5.8 

2006 313.7 5.9 

2005 230.5 4.2 

2004 211.3 3.9 

2003 237.5 4.5 

2002 267.2 5.3 

2001 310.6 5.8 

2000 288.6 5.4 

1999 440.9 8.3 

1998 449.7 8.5 

1997 462.4 9.9 

1996 443.5 9.4 

1995 423.9 9.2 

1994 454.3 9.3 

Table 3.14.3 Air Conditioning & Warm Air Heating & Commercial/Industrial 

Refrigeration Equipment Industry Census Data45 

Year 

End-of-Year Inventory 

(2008$ Mil) 

End-of-Year Inventory as a 

Percentage of Value 

of Shipments (%) 

2008 2,888.0 10.0 

2007 3,101.5 10.5 

2006 3,033.9 9.9 

2005 2,903.7 9.6 

2004 2,777.3 10.0 

2003 2,734.5 10.0 

2002 2,711.2 9.9 

2001 3,092.3 10.8 

2000 3,670.5 11.9 

1999 3,687.6 11.8 

1998 3,346.5 11.2 

1997 3,309.3 11.8 

1996 4,007.4 12.0 

1995 4,035.8 12.8 

1994 3,832.2 12.6 

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

Survey of Plant Capacity from 1994 to 2006. Table 3.14.4 presents utilization rates for various 

sectors of the household appliance industry. Full production capacity is defined as the maximum 

level of production an establishment could attain under normal operating conditions. In the 

Survey of Plant Capacity report, the full production utilization rate is a ratio of the actual level of 

operations to the full production level. The full production capacity utilization rate for household 

appliances in aggregate, along with the rates for household laundry appliances, show a decrease 

in utilization from 1994 to 2006, although trends in subsets of that time period have fluctuated. 

Full production capacity utilization rates for air conditioning and warm air heating and 

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commercial/industrial refrigeration equipment have remained relatively steady over the period 

from 1996 to 2006. Prior to 1996, reported data did not disaggregate these types of equipment 

from more general heating and refrigeration equipment. 

Table 3.14.4 Full Production Capacity Utilization Rates46 

Year 

Rates (%) 

Household 

Appliances Household Laundry 

Air Conditioning & Warm Air Heating & 

Commercial/Industrial Refrig. Equip. 

2006 77 80 63 

2005 74 79 66 

2004 76 77 60 

2003 78 85 62 

2002 72 87 60 

2001 70 90 59 

2000 70 88 66 

1999 75 87 67 

1998 73 75 67 

1997 73 80 66 

1996 76 81 NA* 

1995 79 83 NA* 

1994 82 89 NA* 

* Data not available at this level of disaggregation 

3.15 TECHNOLOGY ASSESSMENT 

This section provides a technology assessment for residential clothes dryers and room air 

conditioners. Contained in this technology assessment are details about product characteristics 

and operation (section 3.15.1), an examination of possible technological improvements for each 

product (section 3.15.2) and a characterization of the product efficiency levels currently 

commercially available (section 3.15.3). 

3.15.1 Product Operations and Component 

In preparation for the screening and engineering analyses, DOE prepared a brief 

description of the characteristics and operation of each product covered by this rulemaking. 

These descriptions provide a basis for understanding the technologies used to improve product 

efficiency. 

3.15.1.1 Residential Clothes Dryers 

Residential clothes dryers are appliances designed to dry clothes by tumbling the load in 

a heated drum to remove moisture by means of evaporation. Because a horizontal axis of rotation 

is required to create the tumble action, residential clothes dryers are generally front-loading. 

Front-loading clothes dryers have an opening on the front of the unit, covered by a door, which 

gives access to an inner cylindrical drum where the load to be dried is placed. The inner drum is 

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perforated and is surrounded by a larger outer housing which collects the moisture-laden air. The 

clothes dryer uses electricity to power an electric motor that rotates the drum within the housing, 

which is contained inside a cabinet. Vanes and/or surface textures may be incorporated into the 

inner surface of the drum to facilitate separation of the clothing to expose surface areas for 

drying. 

Air is drawn through the drum by means of an electrically driven blower. This air stream 

is heated prior to entering the drum in order to evaporate the moisture in the clothing with which 

the air comes in contact. Heating may be provided by an electrically energized resistive element. 

Alternatively, hot air in the drum may be supplied by means of a gas burner system whose 

combustion products are directed into the drum by the electrically powered blower. 

In the case of vented clothes dryers, the moisture-laden air is exhausted from the drum 

through a length of ducting, and as it exits, freshly heated room air is drawn in. The exhaust air is 

typically vented to an exterior location due to its high temperature and relative humidity. In 

installations where exterior venting is not possible, a ventless system may be used in which the 

moist air in the drum is routed through an air- or water-cooled heat exchanger. The water vapor 

condenses on the heat exchanger surface where it is either collected in a removable container for 

disposal by the user or discharged into a drain line. Ventless systems may either open-loop, in 

which the relatively dry air from the drum is exhausted into the room, or closed-loop, in which 

the dry air is recirculated back to the heater and subsequently to the drum inlet. With an air-to-air 

heat exchanger, the ambient air that was used to provide cooling is also discharged back into the 

room at a slightly higher temperature due to the heat transfer from the condensing water. 

Because the exhaust products from gas combustion systems contain a significant amount of 

moisture and varying levels of hazardous emissions such as carbon monoxide, ventless clothes 

dryers are all electrically heated. Tradeoffs associated with ventless versus vented dryers include 

greater flexibility in installation but longer drying times. In addition, for air-to-air systems, space 

conditioning loads may be increased due to the discharge of warm dry air to ambient. This may 

be offset, however, by the fact that conditioned ambient air is not being discharged to the 

exterior, as would be the case for a vented unit. 

Combination washer/dryers combine clothes washing and drying functions in the same 

front-loading tub. The wash and dry cycles are performed in sequence. Since the washing 

function requires a drain hookup, and because these units are often installed where space is at a 

premium and outside access might not be available, all combination washer/dryers currently on 

the market utilize condensation drying. In addition, a water-cooled heat exchanger is made 

possible due to the water hookup already in place for the washing. 

3.15.1.2 Room Air Conditioners 

Room air conditioners are portable, refrigeration-based appliances that enable users to 

cool or warm an enclosed space, room, or zone. In addition to the primary cooling or warming 

function, room air conditioners also reduce the relative humidity (RH) of the conditioned space. 

RH is defined as the amount of water vapor present in the air compared to the maximum amount 

of water vapor the air can hold at that temperature, these amounts being expressed as partial 

3-59 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

pressures of the water vapor. Although they are portable, room air conditioners are designed for 

semi-permanent installation in a window opening or opening in an exterior wall. Room air 

conditioners are classified according to the amount of heat that can be removed from the room 

air during a given time period, called the capacity, expressed in Btu/h. 

Room air conditioners contain refrigeration systems that remove both sensible and latent 

heat (i.e., thermal load associated with water vapor in the air), from room air. The refrigerantside and air-side components are all contained within one cabinet. The refrigerant-side 

components include the evaporator (indoor conditioning coil), the compressor, the condenser 

(outdoor coil), and the capillary tube. These components are all connected with refrigerant 

tubing. The air-side components consist of the fan motor, the evaporator blower, and the 

condenser fan. The cabinet containing both refrigerant-side and air-side components is split into 

an indoor and outdoor side. An insulated divider wall separates the two sides and reduces the 

heat transfer between sides. The indoor components are the evaporator and evaporator blower. 

The outdoor components are the compressor, condenser, capillary tube, fan motor, and condenser 

fan. A single fan motor with a shaft which extends out both ends is generally used to power both 

the evaporator blower and the condenser fan. The motor is located on the outdoor side to isolate 

motor losses from the indoor side. The evaporator blower shaft penetrates the insulated dividing 

wall. 

Refrigeration-based room air conditioners operate as follows, illustrated in Figure 3.15.1: 

1.	 The fan motor drives the evaporator blower and condenser fan simultaneously; 

2.	 Warm air from the room or space is drawn into the indoor side of the unit across the 

evaporator coil, where latent and sensible heat is removed, and the cooled, 

conditioned air is circulated back into the room by the evaporator fan; 

3.	 The heat from the air vaporizes the refrigerant in the evaporator coil. The evaporated 

refrigerant is compressed by means of the compressor; 

4.	 The heated refrigerant is circulated through the condenser coil on the outdoor side of 

the unit, wherein the vapor is cooled by outdoor air being drawn across the coil by 

means of the condenser fan. This cools the vapor to saturation conditions and then 

condenses the refrigerant. 

5.	 The cooled liquid passes through the capillary tube, reducing its pressure. The 

refrigerant flashes to a liquid/vapor mixture, and the temperature drops, consistent 

with the pressure/temperature curve of saturated refrigerant. The two-phase 

refrigerant re-enters the evaporator and the cycle is repeated. 

3-60 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Source: Friedrich CP10E10 Service and Parts Manual47 

Figure 3.15.1 Room Air Conditioner Operation Schematic 

3.15.2 Technology Options 

In order to gain a deeper understanding of the technological improvements used to 

increase the efficiency of residential clothes dryers and room air conditioners, DOE identified 

several possible technologies and examined the most common improvements used in today’s 

market. 

3.15.2.1 Residential Clothes Dryers

 For clothes dryers, DOE will consider technologies identified in the November 1994 

ANOPR (59 FR 56423), supplemented by technologies described in recent trade publications, 

research reports, and manufacturer product offerings. DOE took the technologies listed below 

(Table 3.15.1)—with exceptions noted below—from the November 1994 ANOPR. DOE took the 

modulating gas dryer technology from an April 2005 report by TIAX LLC (TIAX).48 

Additionally, DOE’s preliminary market research indicated the availability of hydronically 

heated clothes dryers, so DOE has decided to include them in the clothes dryer heat generation 

technologies, but notes that significant revisions to the clothes dryer test procedure would be 

required to accommodate them. Specifically, DOE would have to incorporate a number of 

assumptions about the efficiency of the heat generation source used with these dryers. Improved 

air circulation, motor efficiency, and fan efficiency were added as technology options based on 

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comments received during the Framework Document public meeting for this rulemaking held 

October 24, 2007 as well as submitted written comments in response to the framework 

document. DOE also added technology options for reducing standby power, including switching 

power supplies and transformerless power supplies with auto-powerdown, based on its reverse 

engineering analyses. 

Table 3.15.1 Technology Options for Residential Clothes Dryers 

Dryer Control or Drum Upgrades 

1. Improved termination 

2. Increased insulation 

3. Modified operating conditions 

4. Improved air circulation 

5. Reverse tumble 

6. Improved drum design 

Methods of Exhaust Heat Recovery (Vented Models Only) 

7. Recycle exhaust heat 

8. Inlet air preheat 

9. Inlet air preheat, condensing mode 

Heat Generation Options 

10. Heat pump, electric only 

11. Microwave, electric only 

12. Modulating Heat 

13. Water-cooling, ventless electric only 

14. Indirect heating 

Component Improvements 

15. Improved motor efficiency 

16. Improved fan efficiency 

Standby Power Improvements 

17. Switching Power Supply 

18. Transformerless Power Supply with Auto-Powerdown 

The technology options for residential clothes dryers can be broadly grouped into five 

main categories: dryer control or drum upgrades, methods of exhaust heat recovery (for vented 

models only), heat generation options, improvements to components, and options to reduce 

standby power. 

Improved termination 

The standard dryer is assumed to use a timed drying cycle, which automatically turns off 

the dryer after a user-specified time interval. With automatic termination by temperature sensing, 

an exhaust air temperature sensor controls the length of the drying cycle. With automatic 

termination by moisture sensing, the moisture content of the clothes in the dryer is determined by 

sensors that measure conductivity along with an exhaust air temperature sensor. When the 

moisture content is reduced to a level at which these sensors cannot measure accurately 

(generally around 15 percent RMC) a countdown timer is started. After a pre-specified time 

period that is set by the manufacturer, the cycle terminates. Manufacturers indicated in 

discussions with DOE that moisture sensing with electromechanical controls increase the 

accuracy above automatic termination using only temperature sensors. Manufacturers stated that 

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moisture sensing with electronic controls further improves the accuracy of automatic 

termination. 

One method to improve automatic termination via moisture sensing is to improve the 

accuracy of the conductivity sensors at low levels of RMC. This can be done by increasing the 

contact area between the sensor and the clothing, as achieved by one manufacturer by including 

slip rings in the drum design. An adjustable gain control can also be used in the electronics to 

improve the sensitivity; however, this adds significant cost and reliability issues. A second 

method to improve automatic termination is to improve the accuracy of end-of-cycle detection. 

One manufacturer has indicated preliminary energy savings of up to 17 percent through timer 

controls based on new dryer process modeling.49 

The test procedure for dryers allows an energy credit of 12 percent for either temperature 

or moisture sensing relative to time control to terminate drying. There has been some 

controversy as to whether the use of moisture sensors reduces energy consumption relative to 

temperature sensors. A number of sources claim that temperature sensing controls provide 10 

percent real-world energy savings, whereas moisture sensing controls provide 15 percent energy 

savings.50 Based on field measurements conducted by one manufacturer for the previous 

rulemaking, it appears that the test procedure credits are appropriate. 

Increased insulation 

During the drying cycle some parts of the dryer are warmer than the ambient air. 

Insulating the dryer drum reduces the heat lost through conduction, convection, and radiation to 

the surrounding air. During the previous rulemaking, two dryer manufacturers reported an energy 

savings of about 2 percent from the addition of 1 inch of fiberglass insulation around the dryer 

drum. Computer simulations performed by other researchers with a thermal model showed a 6 

percent energy savings.51 However, in recent discussions with DOE, manufacturers indicated that 

there is little to no efficiency improvement associated with adding insulation. 

There is concern that the insulation would eventually degrade, resulting in fiberglass 

particles being drawn into the drum and onto the clothes because dryer air circulation systems 

operate with a negative air pressure in the drum relative to the outside. These particles can cause 

skin irritation. Potential material substitutions for fiberglass include polystyrene, polyethylene, or 

polyurethane foam insulation. They have similar or lower thermal conductivities and do not 

cause skin irritation. 

Modified operating conditions 

Reducing air flow and/or heat input rate changes the efficiency of the drying process. 

Manufacturers may select operating points which match the dryer cycle time to the washer cycle 

time. From an efficiency standpoint, these settings do not necessarily lead to optimum dryer 

operation. By decreasing the air flow rate, the air temperature in the drum, and thus the 

evaporating rate, increases and results in better energy efficiency. Energy savings of as much as 

8 percent have been shown for tests with reduced air flow rates and electric heater inputs, but the 

drying time increased from about 40 to 55 minutes. Tests by the same researchers with only 

reduced heater input (3.3 kW instead of 4.55 kW) yielded no energy savings and increased the 

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drying time from 40 to 56 minutes. For a very low heater input (1.25 kW), energy savings of 

around 5 percent were achieved, but the drying times were very long (112 minutes). 52 

Improved air circulation 

One manufacturer of commercial clothes dryers has claimed that designing the drum to 

improve airflow (i.e., directing and maintaining heat more efficiently) decreases the energy use 

while maintaining the drying performance.q

 However, DOE is unaware of any data quantifying 

the energy savings associated with improved air circulation. 

DOE noted that air flow through the drum in conventional dryers is generally directed 

from the rear to the front of the drum. Based on discussions with a number of manufacturers, a 

small efficiency improvement, between 1 and 2 percent, can be achieved by changing the air 

flow in the drum such that the air flows in through one side on the rear of the drum, and exits on 

the other side of the rear of the drum. 

Dryer booster fans can be installed to increase the airflow in clothes dryers, which 

conceivably increases the rate of forced convection. In cases of long exhaust ducting where the 

static pressure that must be overcome by the dryer fan is increased, incorporating a dryer booster 

can increase the airflow and thus increase drying capacity and reduce energy consumption of the 

clothes dryer. However, the current DOE clothes dryer test procedure uses an exhaust simulator 

with a standard length and geometry and does not account for alternate installation conditions. 

DOE is unaware of any data quantifying the energy savings associated with dryer booster fans. 

Reverse tumble 

Reverse tumble drying spins the drum in both the clockwise and counter-clockwise 

directions. This action is typically carried out at the end of the cycle in order to reduce the 

amount of wrinkling and tangling of the clothes. However, it is possible to reverse rotational 

direction earlier in the cycle to increase the separation of clothing and thus dry the clothes load 

more quickly and evenly. In the description of a patented reverse tumbling method, it is claimed 

that a 10 percent reduction in drying time, and thus energy consumption, could be achieved.53 In 

addition, reversing the drum rotation can prevent “balling” of large items such as sheets, which 

restricts air flow to the center of the item and requires longer drying times. No manufacturer 

indicated they use, or would consider, reverse tumble for increasing efficiency. Tests conducted 

by one manufacturer, however, found that the small size of the test cloths in the DOE test 

procedure prevents balling and thus no energy efficiency benefit can be measured.54 

Manufacturers also noted in discussions with DOE that reverse tumble does not improve 

efficiency, and in some cases can reduce efficiency when the drum is not rotating while it is 

changing directions. 

Improved drum design 

The intrinsic energy efficiency of a clothes dryer can be affected by the design of the 

drum, including the internal vane design.55 Optimized vane design promotes clothing separation 

during tumbling, which can reduce drying times. According to some manufacturers, the surface 

q

 For more information visit www.amdry.com/resources/products/450264%20Solaris%206_06_final.pdf 

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texture of the drum can also enhance clothing separation. Manufacturers noted that such designs 

are performance related features to ensure gentle handling of delicate clothing, but conceivably 

the improvements in clothes separation and aeration could shorten drying times as well. 

However, DOE is unaware of any data quantifying potential energy efficiency improvements 

associated with improved drum design. 

Recycle exhaust heat 

It is estimated that about 20–25 percent of total heat input energy is lost through the dryer 

vent. For the recycle exhaust heat technology option, a portion of the exhaust air stream is 

reintroduced at the dryer air inlet. This recovers a portion of the energy in the exhaust air stream 

and reduces the energy needed to raise the inlet air to drying temperatures. The exhaust air 

suitable for direct recovery would be available only late in the drying cycle when most of the 

moisture is evaporated and the air temperature rises. Therefore, the realizable energy savings are 

significantly less than the theoretical maximum of about 20 percent. The estimated energy use 

reduction for this technology option is 6 percent. 

Recycling of exhaust air late in the dryer cycle can be accomplished using extra duct 

work and mechanical air diverters; however, it presents several technical problems. There is the 

potential for lint accumulation in the duct work and on the clothes. Recycling of exhaust air 

could present a potential fire hazard since some large pieces of lint could enter the heated area. 

For a gas dryer, there is also a potential inability to promote satisfactory combustion. 

Experiments performed with a 230 V electric dryer (with a baseline energy use of over 

3.0 kWh/cycle) showed that energy savings ranged from 10 to 18 percent, depending on the 

fraction of exhaust air recirculated.56 A fine nylon-mesh filter was installed to minimize the 

amount of recirculated lint. These energy savings are greater than one would expect given the 

large quantity of moisture in the exhaust early in the cycle. Additionally, the National Institute of 

Standards and Technology (NIST) testing indicated savings ranged from 3 to 6 percent for this 

option.57 

Inlet air preheat 

For this technology option, a heat exchanger is used to recover exhaust heat energy and to 

preheat inlet air. This system should be feasible for both gas and electric dryers since none of the 

exhaust air re-enters the dryer. Energy savings are achieved either by a faster drying time or by 

reducing the required heater input power. A number of researchers have investigated this 

technology option for clothes dryers. One manufacturer has estimated 2 to 3 percent energy 

savings, while NIST estimated 3 to 6 percent.58 Both of the above experiments were carried out 

in the non-condensing mode. That is, moisture in the exhaust air was not condensed, which 

limited the maximum heat recovery. 

A limitation of this technology option is that a large surface area is required to achieve 

sufficient heat transfer, and that lint may accumulate on these heat transfer surfaces. Although 

every dryer is equipped with a lint filter, considerable lint is still contained in the exhaust air. 

This lint can foul the heat exchanger, decreasing its effectiveness. Additionally, to overcome the 

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increased resistance to air flow, an extra blower is needed at the fresh air inlet or a stronger 

blower in the exhaust air duct is required. 

Manufacturers have also expressed concern that any decrease in exhaust temperature will 

lead to moisture condensation in the exhaust duct, which could result in damage to the exhaust 

duct and dryer, as well as water leakage into the home. Water leakage into the home could lead 

to the health risks from the development of mildew and/or mold. 

Inlet air preheat, condensing mode 

Dryers have been manufactured both in the United States and Europe that utilize a 

condenser to capture some of the sensible and latent heat in the exhaust air stream. For this 

technology option, heat energy from the exiting air is transferred, using a heat exchanger, to the 

cooler incoming air. If the effectiveness of the heat exchanger is high enough, the water vapor in 

the exhaust air will condense. Therefore, more heat energy is transferred than in a sensible heat 

exchanger system as described above. In Europe, condenser dryers have been used in an open 

system to supply space heat during the winter. In the United States, they have been used to avoid 

the need for vents in apartments. Research has shown that compared to a conventional air vented 

dryer, an open-cycle condensing dryer is about 14 percent more efficient and a closed-cycle 

condensing dryer is 7 percent more efficient.59 Manufacturers have indicated that only minimal 

(1 to 3 percent) efficiency improvement can be achieved with inlet air preheat. 

Manufacturers have identified several problems with this technology option: 1) a drain 

for the moisture is required; 2) lint accumulation on the heat exchanger reduces the heat transfer 

efficiency; and 3) lint can accumulate and clog the drain. Because a drain is required to be 

installed, and humid operating conditions require extensive use of stainless steel or glass in the 

heat exchanger to avoid corrosion, manufacturer cost for this technology option will be greater 

than for the inlet air preheat with a sensible heat exchanger. 

An alternative approach to capture heat from the exhaust air stream is to mechanically 

compress the exhaust air to extract water vapor and transfer the latent heat to the remaining 

gaseous steam. The extracted water is drained from the compression chamber, and the 

pressurized gaseous steam is allowed to expand and be superheated before being injected back 

into the drum to help preheat the inlet air. Researchers have claimed that such a compression 

condenser dryer is as energy efficient as a heat pump dryer, but has almost half the cycle time 

and requires fewer specialized components.60 

Heat pump, electric only 

Heat pump dryers function by recirculating the exhaust air back to the dryer while 

moisture is removed by a refrigeration-dehumidification system. A heat pump dryer is essentially 

a dryer and an air conditioner packaged as one appliance. No heating element is needed. The 

warm and damp exhaust air of the dryer enters the evaporation coil of the dehumidifier where it 

cools down below the dew point, and sensible and latent heat are extracted. The heat is 

transferred to the condenser coil by the refrigerant and reabsorbed by the air, which is moving in 

a closed air cycle. A drain is required to remove the condensate; however, one is usually 

available since clothes washers and dryers are typically located side by side. Heat pump dryers 

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have been unable to penetrate the market despite showing significant energy savings (in some 

cases over 50 percent compared to electric resistance dryers), even in Europe, where they have 

been in existence for years. Based on a recent study, heat pump dryers had a market share of only 

0.3 percent in Western Europe in 2005.61 The major issue for heat pump dryers has been cost and 

performance. Heat pump dryer dry times are typically significantly longer than those associated 

with standard U.S. electric dryers. 

A heat pump dryer has been developed by a U.S. company which has successfully tested 

several prototypes and found energy savings of 68 percent as compared to energy use by a 

conventional electric clothes dryer. The estimated retail cost is approximately twice that of a 

conventional electric dryer. Drying times were essentially the same as for the conventional dryer, 

and the dryer operates on standard 120 V line power. The prototype uses a disposable filter to 

reduce lint in the air system. One inch of polyisocyanurate insulation was used to avoid 

condensation of water vapor in the recirculated air. In addition, the extension on the back of the 

prototype dryer to accommodate the added refrigeration components was estimated to be about 

the same depth as a vent duct, so the cabinet may fit in the same space as a conventional dryer. 

More maintenance will probably be required for a heat pump dryer than for a 

conventional dryer. The heater is replaced by equipment found in a small room air conditioner— 

a condenser, evaporator, compressor, expansion valve, etc. Installation costs, though, may be less 

than for a conventional electric dryer because the heat pump dryer does not require an exhaust 

vent as does a conventional dryer (although some heat pump dryers may still use a vent). 

However, heat pump dryers require access to a drain for removal of condensate. 

Research conducted on both heat pump dryers and conventional vented dryers on the 

European market showed that heat pump dryers consumed about 50 percent less energy than 

conventional dryers. The heat pump dryers tested had energy efficiency values between 0.32 and 

0.40 kWh/kg laundry (with 70 percent initial moisture, measured according to test standard EN 

61121) whereas conventional dryers had values between 0.6 and 0.8 kWh/kg laundry. Another 

benefit noted by this research was that the leakage of water vapor into the room was around 20 

percent, which is significantly lower than conventional dryers. This research performed a cost 

comparison of heat pump dryers versus conventional dryers, which showed that the combined 

sale price and electricity costs over 15 years was about 1900 and 2300 Euros, respectively. 62 

Research sponsored by TIAX and Whirlpool developed a high efficiency, highperformance heat pump clothes dryer for the U.S. market. This different approach to the heat 

pump system maximized the output capacity and temperature from the heat pump. This design 

has shown 40 to 50 percent energy savings on large loads along with 35 degree Fahrenheit (°F) 

lower fabric temperatures and similar dry times. For delicate loads, the design reduced fabric 

temperature by 10–30 °F and provide up to 50 percent energy savings and 30–40 percent drying 

time savings. The heat pump dryer designed by TIAX also exhibited improved fabric 

temperature uniformity as well as robust performance across a range of vent restrictions in a 

partially open-loop design described below.63 

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In order to maximize the air inlet temperature and airflow into the dryer’s drum, TIAX 

replaced the standard refrigerant, R-22, with R-134a in an R-22 air conditioner/heat pump 

compressor, shifting evaporating and condensing temperatures by 30 °F while maintaining 

similar operating pressures and power input. TIAX was also able to maximize the capacity of the 

heat pump system by redesigning the heat exchanger components to optimize space utilization 

and increasing the airflow in the system as compared to typical dryers.64 

A key issue in the TIAX design was the venting options of the heat pump dryer. The 

moisture in the air exiting the drum is removed by the evaporator. This air can then be 

recirculated back into the drum, which removes the need for a vent. However, some form of heat 

rejection is required since the heat pump generates more heat than cooling in steady state 

operation. TIAX used a partially open-loop design in which a portion of the process air is vented 

outdoors to remove excess heat. In this design, all of the process air is recirculated through the 

dryer until the system has fully warmed, at which point the exhaust is opened and a portion of 

the total flow is vented to the outside.65 

Microwave, electric only 

Microwave energy can be absorbed by water, thereby heating the water enough to cause 

evaporation. This would be a direct and efficient manner to remove moisture from clothes. 

Prototype microwave dryers have been built and tested. The previous rulemaking determined 

that energy savings from the use of a microwave dryer would be approximately 26 percent 

compared to a conventional dryers. The data was provided by a company developing a prototype 

microwave dryer, and the developers claimed that the system could safely dry clothes with metal 

buttons and zippers, although clothes with metallic threads could be damaged. Uniform drying is 

also a problem since the microwaves may not reach the interior of the clothing container. The 

prototype dryer described above utilized two magnetrons for delivering the microwave energy to 

the drum. 

Instead of the conventional method of passing warm air over the clothes, microwave 

energy can be directly absorbed by water retained in the clothing, thereby heating the water 

enough to cause evaporation. Microwave drying uses the principle of dielectric heating, in which 

electromagnetic energy is radiated into the dryer drum where it is absorbed by water molecules 

which have a higher dielectric loss factor than most common fabric materials. Most fabric 

materials are also relatively transparent to microwave energy, so that the microwaves can 

penetrate the fabric’s interior to heat the water molecules directly. This allows the fabric in a 

microwave dryer to stay cooler—below 115 °F—as compared to conventional dryers which heat 

air to approximately 350 °F, with fabric surfaces reaching 150 °F. Microwave dryer prototypes 

have been shown to consume about 17 to 25 percent less energy as well as to dry clothes about 

25 percent faster than conventional electric dryers.66 

Early conceptualization of this technology began in the mid-1960s; however, product 

development was not pursued because of high manufacturing costs and difficulties in 

overcoming hazards relating to arcing and overheating of clothing. In 1997, the Electric Power 

Research Institute (EPRI) focused on developing a compact countertop dryer based on economic 

feasibility and market surveys. EPRI market studies and the development of prototypes for in3-68 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

house evaluation have led to negotiations for technology licensing and indications of serious 

product development for a residential microwave clothes dryer.67 

Because of the interaction between the metallic sensor contacts and the electromagnetic 

field, microwave dryers are incapable of using contact moisture sensors as in conventional 

dryers. EPRI investigated using sensors to detect the microwave electric field strength and the 

fabric temperature, which both correlate well with the moisture content. As evaporation nears 

completion, both measured signal slopes begin to rise in a predictable manner, so that the dryer 

can be shut off automatically and avoid wasted energy in over-drying clothes.68 

Microwave drying also introduces a safety concern related to arcing. Arcing is caused by 

an electric field which induces a voltage differential between metal objects, allowing current to 

flow within them. The resultant heating and sparking of the metal objects may ignite a fire in the 

load. EPRI has developed a rapid-response gas sensor to detect small amounts of gaseous byproducts of combustion in the exhaust stream. Upon detection, the drying cycle can be shut down 

immediately, preventing safety hazards and damage. Another technique to avoid arcing is to 

switch to electric resistance heaters when the clothes are almost dry.69 

Modulating Heat

 Most gas dryers on the market operate with a single burner at a fixed input rate and a 

fixed airflow rate in an on/off mode based on the cycle chosen and the temperature of the 

exhaust flow. Based on a modulating gas dryer design jointly developed by TIAX and 

Whirlpool, a reduction of energy consumption of up to 25 percent for small and medium loads 

has been shown. For large loads, a reduction in energy consumption of 10–15 percent has been 

shown as well as up to 35 percent drying time savings, with no adverse effect on cloth 

temperature. For delicate loads, modulating gas dryers are able to reduce fabric temperatures as 

well as dry times, achieving an 18 percent reduction of energy consumption. Along with these 

performance characteristics, modulating gas dryers would provide robust performance across a 

range of vent restrictions.70 

A key consideration in the design of a modulating gas dryer is matching the heat input 

rate to the moisture level of the load. The design developed by TIAX used a maximum gas input 

rate of 40,000 Btu/h using two inshot burners firing into a combustion chamber that was larger 

than in a conventional gas dryer. The gas input rate was able to be modulated to three different 

levels: (1) high (40,000 Btu/h), (2) medium (rate similar to conventional gas dryers), and (3) low 

(rate less than half of a conventional gas dryer). The burners were positioned so that they fired 

into an oval-shaped combustion funnel before turning upwards into the rear duct and entering the 

drum. A downstream blower was used to induce airflow into the drum. A new funnel/collar/rear 

duct was designed to deliver evenly distributed and improved air flow to increase efficiency, 

while being able to be manufactured with minimal modifications to existing plant tooling.71 

TIAX utilized a variable speed blower to deliver varying airflow rates to match the 

following general dryer cycles: (1) heavy duty, (2) normal, and (3) delicate. In order to account 

for airflow changes and resultant pressure drops associated with installation variations, the 

system used a pressure switch in the exhaust flow stream from the dryer. The blower speed 

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would be increased at the beginning of the dry cycle until the pressure switch was tripped, 

providing an indication of the level of exhaust restriction.72 

Control of this system was achieved via a temperature and humidity sensor in the 

exhaust. Since the flow rate would be known, the temperature in the exhaust would be used to 

infer the amount of moisture inside the drum. The temperature signal would thus be used to 

determine when to perform the first and second modulation steps. In addition, this temperature 

signal, combined with the output from a humidity sensor in the exhaust, could be used to 

determine the end of the cycle.73 

Modulating heat can also be implemented in an electric clothes dryer. The electric 

resistance heater could be accurately controlled by an electronic controller that incorporates a 

bidirectional triode thyristors (Triacs) or similar solid-state approaches to control the heat output. 

Water-cooling, ventless electric only 

For this technology option, an internal water-cooled condenser heat exchanger system 

condenses the water vapor in the air exiting the drum. This design is similar to conventional 

condenser heat exchanger systems used in clothes dryers in which the exhaust heat is recirculated 

back to the dryer, except that the cooling fluid is water, not air. On the market in Australia, 

water-cooled condensers are generally used in combination washer/dryers whereas air-cooled 

condensers are used in stand-alone dryers. According to a report prepared for the Department of 

the Environment and Water Resources in Australia, for combination washer/dryers using watercooled condensers, the amount of water required for condenser cooling can be as much or more 

than as is used for the wash cycle.74 In addition, this technology option would require a drain for 

the removal of condensate as well as plumbing to the supply water. DOE is unaware of any data 

quantifying potential energy efficiency improvements associated with improved drum design. 

Indirect heating 

For indirect heating, the clothes dryer heat energy is derived from the home’s heating 

system. This technology option uses a residence’s hydronic heater system to heat water which 

then flows through a heat exchanger in the dryer, heating the air entering the drum. Significant 

plumbing would be required to circulate heated water through the heat exchanger in the dryer. 

DOE is unaware of any data quantifying potential energy efficiency improvements associated 

with indirect heating. 

It is possible that a stand-alone hydronic heater could be implemented as a clothes dryers 

heat source. One source claims that water or other heat transfer fluids could be heated using an 

immersion element similar to a water heater. The heated fluid passes through a heat exchanger, 

where the heat is transferred to the air entering the drum, and is then pumped back to the 

hydronic heater. The source claims that a hydronic heating clothes dryer uses 50 percent less 

energy and dries the clothing load up to 41 percent faster than conventional clothes dryers.75 

Improved motor efficiency 

Clothes dryers generally use a single motor which functions to turn the drum as well as to 

power the blower in order to draw air through the drum and out the exhaust vent. The typical 

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clothes dryer uses a 1/3 horsepower four-pole induction motor. Based on DOE testing, about 5 

percent of the total electrical energy consumed by a typical clothes dryer is used by the electric 

motor to drive the drum and the blower. Manufacturers stated that improving the efficiency of 

the motor can increase overall efficiency by 1 to 5 percent. Manufacturers also indicated that 

using an electronically-commutated motor (ECM) is very expensive and provides minimal 

efficiency improvement. 

A number of manufacturers indicated that they use separate motors to drive the drum and 

the blower fan with a permanent split capacitor motor or brushless permanent magnet motor in 

some models in order to adjust air flow rates based on different exhaust vent installations to 

improve performance. However, they indicated that because the DOE test procedure uses a 

standard exhaust simulator (as indicated above), there would be no benefit to efficiency. DOE 

believes that such a split motor design which can adjust air flow rates implemented designs such 

as a modulating heater could conceivably improve efficiency. 

Improved fan efficiency 

Clothes dryers generally use an electrically driven fan blower to draw air through the 

drum. Increasing the efficiency of this blower could reduce the clothes dryer energy 

consumption. A blower fan with rear curved blades (as opposed to conventional forward curved 

blades) could conceivably provide more consistent air flow and improve efficiency. However, 

DOE is unaware of any data quantifying the potential energy efficiency improvements associated 

with an improved blower fan, distinct from improvements in its drive motor. 

Switching Power Supply 

A potential area for standby power improvement is the power supplies on the control 

board. A typical clothes dryer may use an unregulated plus regulated control board power supply 

(also referred to as a linear power supply). The unregulated portion consists of a small 

transformer, a bridge rectifier, and an electrolytic capacitor. Voltage regulators then step down 

the voltage(s) to the level(s) required by the control logic, display, and cooking sensor. This 

approach results in a rugged power supply which is reliable, but typically has an efficiency of 

about 55 percent. 

Switching power supplies offer the highest conversion efficiencies (up to 75 percent) and 

lowest no-load standby losses (0.2 W or less), though at a higher cost, higher part count, and 

greater complexity. Switching power supplies convert power differently than conventional linear 

power supplies. Switching power supplies first rectify the alternating current (AC) mains voltage 

to direct current (DC), converting it back to AC by switching the current on and off at high 

frequency. The high-frequency AC current passes through the primary winding of a transformer 

while the output from the secondary winding of the transformer is rectified, resulting in a lowvoltage DC output. Because the AC current passing through the transformer is at high frequency, 

the transformer is smaller and has lower standby losses. Switching power supplies greater 

complexity may also result in lower overall reliability and take greater care to implement. For 

example, among other issues, a switching power supply can be prone to causing electromagnetic 

interference. However, DOE noted in its reverse engineering teardown analysis that there are a 

large number of clothes dryers on the U.S. market that incorporate switching power supplies. 

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Transformerless Power Supply for Auto-Powerdown 

DOE’s reverse engineering teardown analysis suggests that very low standby levels can 

be achieved by implementing a transformerless power supply for the microprocessor logic, along 

with a conventional power supply that is activated when the unit goes into active mode. Such a 

power supply design, incorporated with a “soft” power pushbutton and triac to control power 

through the transformer, would provide just enough power through the transformerless power 

supply to maintain the microcontroller chip while the clothes dryer is not powered on. When the 

power button is pressed, current would then be allowed to pass through the transformer of the 

conventional power supply to power the remainder of the control board. DOE is unaware of any 

data indicating the reliability of such a design. 

3.15.2.2 Room Air Conditioners

 For room air conditioners, DOE considered technologies identified in its last standards 

rulemaking that culminated in the September 24, 1997, final rule. 62 FR 50122. With the 

exception of microchannel heat exchangers and hydrophilic-film coating on fins, DOE has 

determined that the technologies listed in Table 3.15.2 have not changed appreciably since 

DOE’s TSD was published in September 2007. With regard to microchannel heat exchangers, 

research conducted at the University of Illinois has demonstrated that this technology can be 

applied to room air conditioner applications.76 Hydrophilic-film coating on fins was identified in 

an analysis of energy efficiency in Chinese room air conditioners conducted jointly by Lawrence 

Berkeley National Laboratory, the China National Institute of Standardization (CNIS), and the 

Beijing Energy Efficiency Center (BECon).77 

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Table 3.15.2 Technology Options for Room Air Conditioners 

Increased Heat Transfer Surface Area Technology Passed to Screening Analysis? 

1. Increased frontal coil area Yes 

2. Increased depth of coil (add tube rows) Yes 

3. Increased fin density Yes 

4. Add subcooler to condenser coil Yes 

Increased Heat Transfer Coefficients 

5. Improved fin design Yes 

6. Improved tube design Yes 

7. Hydrophilic-film coating on fins Yes 

8. Spray condensate onto condenser coil Yes 

9. Microchannel heat exchangers Yes 

Component Improvements 

10. Improved indoor blower and outdoor fan efficiency Yes 

11. Improved blower/fan motor efficiency Yes 

12. Improved compressor efficiency Yes 

Part-Load Technology Improvements 

13. Two-speed, variable-speed, or modulating-capacity 

compressors 

Yes 

14. Thermostatic or electronic expansion valves Yes 

15. Thermostatic cyclic controls Yes 

Standby Power Improvements 

16. Switching Power Supply Yes 

Refrigeration System Options 

17. Alternative Refrigerants (R-407C) No 

18. Suction-Line Heat Exchanger No 

As shown in Table 3.15.2, design improvements to improve energy efficiency can be 

categorized according the following six methods: increasing heat transfer performance by either 

increasing heat transfer surface area or the heat transfer coefficients, improvements upon 

individual components, part-load technology improvements, standby power improvements, and 

refrigeration system options. 

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Technology options that are intended to improve efficiency under cycling or part-load 

conditions cannot be evaluated under the current DOE test procedure which specifies steadystate test conditions. Technology options such as variable speed compressors, electronic 

expansion valves, and cyclic controls improve efficiency in central air-conditioning (CAC) 

systems. CAC products are rated using a seasonal efficiency metric (the seasonal energy 

efficiency ratio, SEER), which takes into account the efficiency of the product while operating 

under part-load conditions. However, CAC operating conditions are different than those 

experienced by room units. CAC units typically are generally active during the entire cooling 

season, ready to be turned on by the thermostat when there is a call for cooling. In contrast, room 

air conditioners are generally turned on when the room temperature is high, thus reducing the 

amount of cycling as compared to CAC systems. Manufacturers have commented that room air 

conditioners have become a commodity item that is typically undersized for the room in which it 

is installed, and thus increasing their tendency to operate mostly in on/off mode. Measurement of 

part load efficiency has not been integrated into the room air conditioner efficiency metric, 

because of the low probability that greater use of part-load technologies will be used and/or will 

save energy. Hence, the potential for energy-savings benefits from technology options that 

reduce energy consumption during part load conditions cannot be evaluated using the new 

efficiency metric, CEER, on which the engineering analysis is based. 

DOE added technology options 17: R-407C as a refrigerant, and 18: Suction-Line Heat 

Exchanger (SLHX) in response to stakeholder comments during the preliminary phase of the 

rulemaking. 

Table 3.15.2 indicates which technologies DOE considered suitable for further analysis. 

These are the technologies that DOE passed to the screening analysis for further review. The 

reasons that certain technologies were not passed to the screening analysis are provided in the 

individual technology descriptions below. 

Technologies Passed to the Screening Analysis 

Increased frontal coil area 

One of the most common ways of increasing heat transfer surface area is by using a coil 

with a larger frontal area. With a greater amount of coil face area, the heat transfer performance 

of the coil is increased. For the condenser, the required heat can be rejected from the refrigerant 

to the outside air stream at a lower condensing temperature. For the evaporator, the specified 

cooling capacity can be delivered to the room at a higher evaporator temperature. These changes 

reduce the pressure difference between the low pressure and high pressure sides of the system 

which the compressor must overcome, thus reducing compressor power input. However, a tradeoff associated with increased evaporating temperature is that the evaporator’s ability to 

dehumidify the air may be compromised. 

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Increase of coil frontal area is limited in many situations by the size constraints for the 

room air conditioner, particularly for large-capacity and through-the-wall products (i.e., products 

without louvered sides). 

Increased depth of coil (add tube rows) 

Heat transfer surface area may also be increased by adding rows of tubes to the coil. In 

the previous rulemaking, manufacturers asserted that each room air conditioner chassis is 

designed for a maximum-depth evaporator and condenser. Vertical tube rows may be added up 

to that maximum depth, however adding more rows would require an increase in the size of the 

chassis, which incurs significant costs beyond just the costs of the larger heat exchanger. 

Other issues associated with increase of heat exchanger depth include the need to 

minimize weight, the added refrigerant charge, decreasing improvement associated which each 

additional tube row, and the airside pressure drop. With regard to weight, manufacturers claimed 

that there is a practical limit to the depth of a room air conditioner which is related to weight, 

appearance, and strength of the mounting. The increase in refrigerant charge combined with the 

increased effectiveness of the heat exchangers can lead to risk of compressor failure. The room 

air conditioner may require a smaller-capacity compressor to meet the specified cooling load. 

Smaller compressors have lower refrigerant charge limitations to avoid problems such as oil 

frothing during startup, so the changes could impact the reliability of the compressor. 

Manufacturers asserted in the previous rulemaking that each successive row in a coil is only 

about 70 percent as effective as the preceding row, thus adding rows to a three- or four-row heat 

exchanger has a small effect on system efficiency. Finally, increasing heat exchanger depth can 

reduce air flow, which can negate any benefit associated with the additional heat exchanger 

surface area. 

Increased fin density 

Another method of increasing the heat transfer surface area is to increase the fin density. 

Increased fin density improves the heat transfer; however, its effect on air flow, fan power, water 

drainage, and dirt build-up places a limit on how much the density can be increased. 

Fin density has a direct effect on the fan power required to draw or blow air over the coil. 

Increasing the fin density increases the air-side pressure drop over the coil, resulting in more 

power being used by the fan motor. Any reduction in air flow can negate the improvement in 

heat transfer associated with increased fin density. Increased fin density also can increase water 

retention in the evaporator. The condensate that forms on the evaporator must flow down to the 

drain pan by the effect of gravity. Increased fin density can limit the condensate flow, which can 

restrict air flow and lead to entrainment of water droplets in the discharge air flow. The build-up 

of dirt on heat exchanger surfaces is accelerated by an increase in fin density. Smaller air 

passageways through the coils are more likely to retain dirt which, if allowed to accumulate over 

a unit’s life, decrease the system performance. Taking these factors into consideration the 

maximum fin density is a function of the type of coil (i.e., evaporator or condenser), the fin type 

(i.e., wavy, louvered, or enhanced), the number of tube rows, and the tube diameter. 

Add subcooler to condenser coil 

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Subcoolers are added between the condenser coil outlet and the capillary tube inlet and 

are submerged near the condenser in the condensate produced by the evaporator. Adding a 

subcooler effectively increases the size of the condenser coil as it further cools the refrigerant 

coming out of the condenser. However, finding the space to incorporate a subcooler into a room 

air conditioner can be difficult..They are used much more frequently in larger-capacity units, 

which have more space for them. 

In the previous rulemaking, manufacturers supplied data for evaluating subcoolers as a 

design option. The data from the 1997 TSD analysis is recreated in Table 3.15.3, which shows 

the manufacturer test results on the performance improvements due to adding a subcooler. Using 

a representative baseline for each product class, specifications were given on how large a 

subcooler could be to be incorporated into the existing baseline design. In addition, 

manufacturers provided test data detailing the effect on capacity, power consumption, and 

efficiency due to the addition of a subcooler. For each product class, the percentage change in 

efficiency was used to establish the efficiency gain due to adding a subcooler. Test data was not 

provided for classes with reverse cycle. 

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Table 3.15.3 Manufacturer Test Results from 1997 TSD Analysis: Performance 

Improvements due to Subcoolers 

Product Class 

Before Subcooler Added Percent Change with Subcooler Added 

(%) 

Capacity 

(Btu/h) 

EER (Btu/Wh) Capacity 

(Btu/h) 

Power 

(kWh) 

EER 

(Btu/W-h) 

Louvered side w/o reverse cycle 

less than 6,000 Btu/h 6,338 9.19 1.0 -2.0 2.9 

Louvered side w/o reverse cycle 

6,000 to 7,999 Btu/h 7,461 8.50 1.7 -1.3 3.0 

Louvered side w/o reverse cycle 

8,000 to 13,999 Btu/h 

9,984 9.20 -0.8 -1.1 1.0 

11,668 9.00 0.8 -0.9 1.8 

Average Change for Product 

Class: 0.0 -1.0 1.4 

Louvered side w/o reverse cycle 

14,000 to 19,999 Btu/h 

18,351 9.70 2.0 0.0 2.1 

18,984 9.70 1.5 -0.2 1.6 

17,954 9.71 1.1 -0.3 1.4 

Average Change for Product 

Class: 1.5 -0.2 1.7 

Louvered side w/o reverse cycle 

greater than 20,000 Btu/h 

24,319 8.00 0.9 -1.0 1.9 

34,947 8.00 0.3 -0.6 1.0 

Average Change for Product 

Class: 0.6 -0.8 1.5 

No louvered side w/o reverse 

cycle 

6,000 to 7,999 Btu/h 

6,204 8.91 0.5 -1.3 1.8 

No louvered side w/o reverse 

cycle 

8,000 to 13,999 Btu/h 

11,300 8.51 0.2 -2.6 2.8 

A study for the Directorate-General for Energy (DGXVII) of the Commission of the 

European Communities used a simulation model to calculate the impact of individual technology 

options on a room air conditioner’s performance. The results of the simulation showed that the 

addition of a subcooler to the condenser coil resulted in a 1 percent average increase in EER.78 

Improved Fin Design 

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Improvements to the fin design may have the effect of improving the coil’s air-side heattransfer coefficient, and thus improving the overall heat-transfer capability of the coil. This 

improvement can be due to the increase in air turbulence over the coil caused by the enhanced 

fin design. Manufacturers commented in the previous rulemaking that most room air 

conditioners use some form of fin enhancement in their coil designs already. This fin 

improvement is generally achieved by using louvered, lanced, or slit-type fin surfaces. 

Specific attention to evaporator design regarding condensate runoff and fin patterns may 

increase room air conditioner energy efficiency. It is useful for the evaporator to be designed 

such that condensate runs off effectively and does not adhere to the surface. In addition to 

allowing less entrainment of liquid droplets into the air stream, effective condensate runoff 

results in higher heat transfer between the evaporator and the air and allows higher air flow, thus 

increasing evaporator performance. 

Improved Tube Design 

Improvement of the refrigerant-side heat-transfer coefficient is accomplished by 

augmenting the inside surface of the refrigerant tubes with spiral grooves. This type of 

refrigerant tubing is known as rifled or grooved tubing. Research has shown that the refrigerantside heat-transfer coefficient for grooved tubing is significantly greater than that of conventional 

smooth tubing. As seen with fin enhancements, manufacturers of refrigerant tubing have 

developed various types of grooved tubing to improve the heat-transfer capability of air 

conditioning coils. Improvement to the refrigerant-side heat-transfer coefficient is a function of 

width, height, and spacing of the grooves as well as the concentration of lubricant oil being 

circulated within the refrigerant. As discussed in the 1997 TSD, statistical equations have been 

developed which can predict the benefits of rifling.79 

Hydrophilic-film coating on fins 

The condensate water that forms on heat exchanger fins may adhere to the surface as 

droplets and cause bridging of the fin spacing, resulting in decreased heat transfer performance 

and increased air pressure drop. Adding a hydrophilic coating to heat exchanger fins gives them 

an affinity for water, which reduces the condensate layer thickness. This helps the water to flow 

down the fins and fall off the evaporator quickly, resulting in reduced air-side pressure drops and 

increased airflow rates across the heat exchanger.80 Hydrophilic-film coating on heat exchanger 

fins have been shown to reduce air-side pressure drop 20 to 50 percent when operating with 

high-humidity room-side air. DOE is unaware of any publicly available data quantifying the 

energy efficiency improvements associated with hydrophilic-film coating on fins under normal 

room air conditioner operating conditions. 

Spray condensate onto condenser coil 

The condensate that forms on and drips off of the evaporator coil is collected in a 

condensate pan. Part of the pan is positioned near the condenser and is placed directly 

underneath the condenser fan. The condenser fan is equipped with a slinger ring, which is 

located at the fan blade tips and is able to collect and spray the condensate onto the condenser 

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coil as the fan rotates. The spray provides evaporative cooling to enhance the performance of the 

condenser. 

Microchannel heat exchangers 

Unlike a conventional coil tube with an attached plate fin, microchannel heat exchangers 

have a rectangular aluminum cross-section containing several small channels (typically less than 

1 millimeter across) through which refrigerant passes. Aluminum fins are brazed between the 

rectangular tubes. Microchannel can increase heat transfer while reducing pressure drop as 

compared with conventional coils. Microchannel heat exchangers generally weigh less and hold 

significantly less refrigerant than conventional heat exchangers. 

Currently there are several manufacturers of microchannel heat exchangers. The 

technology was first used in automobile air conditioning systems, where it is used almost 

exclusively for condensers. Other air-conditioning applications are adopting the technology, 

particularly in applications requiring reduced size and weight. These include military 

environmental control units (ECUs), air-cooled chillers for commercial buildings, and some 

residential central air conditioning systems. However, microchannel heat exchangers have not 

yet been adopted by room air conditioner manufacturers. A key issue for use in room air 

conditioner applications is the much higher investment cost required for the equipment needed to 

fabricate these heat exchangers (i.e., brazing ovens) as compared with equipment used for 

fabrication of conventional heat exchangers. 

Microchannel heat exchangers have traditionally had difficulty in evaporator 

applications, because their geometry is less amenable to condensate removal than conventional 

heat exchangers. When installed with the headers oriented vertically, the horizontal flat fins 

between fin sections block gravity flow of condensate. Also, even distribution of expanded twophase refrigerant into the many parallel flow paths through the tubes is challenging. While these 

issues can be alleviated by orienting the evaporator with the headers horizontal, such an 

orientation is undesirable for many applications. 

Research has compared the performance of a window-mounted room air conditioner with 

microchannel condensers to a baseline system with a conventional finned-tube condenser. The 

results showed the heat transfer rates per unit core volume of the microchannel heat exchangers 

were 14 to 331 percent higher than the conventional finned-tube heat exchangers. However, the 

overall efficiencies of two systems using the microchannel condenser heat exchanger were 1 to 3 

percent lower than the baseline system. The lower efficiencies attained by this work were 

believed to be due in part to the un-optimized condensate slinger ring and smaller subcooling of 

the microchannel systems. The results did show reductions in refrigerant charge, condenser core 

volume, and weight of 35, 55, and 35 percent, respectively, using microchannel condensers.81 

Improved indoor blower and outdoor fan efficiency 

The air delivery system of a room air conditioner consists of one motor driving two fans, 

the indoor blower (evaporator), and outdoor (condenser) fans. The evaporator blower is typically 

a centrifugal blower, while the condenser fan is a propeller-type fan with a slinger ring attached 

to it. As mentioned earlier, the slinger ring sprays condensate onto the condenser coil. 

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Improvements to the fan designs to improve air flow characteristics could increase the overall 

efficiency by decreasing the power demands for the fan motor. 

Fans and blowers are generally molded plastic parts with fairly advanced geometries as 

compared with stamped sheet metal designs of the past. The condenser fan is mounted with 

reasonable clearance to the fan orifice, which is typically sheet metal which may have a formed 

bell mouth in the region of the fan blade tips. The evaporator blower is generally housed inside a 

Styrofoam enclosure which is shaped to provide smooth flow of air into and out of the blower. 

The Styrofoam doubles as thermal isolation between the indoor and outdoor sides of the unit. 

Air system efficiency could possibly be improved through more advanced fan and blower 

design. It could also be improved by reducing the restrictions to air flow. However, the space 

limitations within room air conditioners make reduction of flow resistance difficult. Adjustments 

to the designs of the heat exchangers can affect air flow, as discussed in the sections addressing 

heat exchangers above. 

Improved blower/fan motor efficiency 

Room air conditioners primarily use permanent split capacitor (PSC) fan/blower motors. 

These motors range in efficiency from 45 to 70 percent. While larger motors are generally more 

efficient, there is a range of efficiency for any given power level. 

Electric motors operate based on the interaction between a field magnet and a magnetic 

rotor. However, single-phase motors only produce a rotating magnetic field when the rotor is 

rotating, and simply powering the electromagnet is therefore not sufficient to start such a motor. 

One of the most significant differences between different types of single-phase motors is the way 

in which they handle start-up. In a PSC motor, a small start-up winding is present which is 

energized out of phase with the main winding. The start-up winding is electrically connected in 

parallel with the main winding and in series with a capacitor. At start-up, the interactions 

between the magnetic field generated by the start-up winding and that generated by the main 

winding induce rotation. As the capacitor charges, the current flowing through the start-up 

winding decreases, and the start-up winding becomes an auxiliary winding after the motor 

reaches running speed. Consequently, the current to the start-up winding is cut off once the 

capacitor is fully charged and the motor reaches steady-state speed. PSC motors are produced in 

large quantities and are relatively inexpensive.82 

Permanent magnet motors have higher efficiencies than PSC motors. For the purposes of 

this report, they will be called brushless DC (BLDC) motors. They are also known as ECMs, 

brushless permanent magnet (BPM) motors, and electronically-commutated permanent magnet 

(ECPM) motors. BLDC motors are more efficient than PSC motors. BLDC motors convert 

single-phase AC input power into DC power and achieve the commutation required for operation 

of DC motors by electronic switching rather than through use of a conventional mechanical 

commutator. The commutation is coordinated through use of sensor technology that determines 

when the motor is at the proper angle for switching the power. BLDC motors have efficiencies 

approaching 80 percent.83 However, BLDC motors can weigh more than PSC motors of the same 

shaft power, potentially necessitating a redesign of the room air conditioner chassis to 

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accommodate the increased weight. In addition, BLDC motors are more expensive than PSC 

motors. 

Improved compressor efficiency 

Most room air conditioners are now made with hermetic rotary compressors. Rotary 

compressors have displaced reciprocating compressors, because they are smaller, weigh less, and 

have reduced noise and vibration. Compressors for room air conditioners traditionally used a 

hydrochlorofluorocarbon (HCFC) refrigerant, designated HCFC-22. Maximum rotary 

compressor efficiencies for HCFC-22 refrigerant range from 10.7 to 11.2 EER. However, due to 

the phaseout of HCFC-22 for new products that took place starting in 2010, room air 

conditioners have switched to R-410A refrigerant, which is a blend of hydrofluorocarbon (HFC) 

refrigerants that do not contain chlorine. The room air conditioner market has lagged central air 

conditioners in the transition to R-410A. Compressor manufacturers have developed rotary 

compressors for the new refrigerant, but the product lines initially available did not span the 

applicable capacities and efficiency levels for room air conditioners fully. Hence, while room air 

conditioner manufacturers may have had multiple compressor options of varying EER to 

consider in the design of a unit using HCFC-22, there may initially have been only one option 

with appropriate capacity for the design of a unit using R-410A. This compressor availability 

issue improved as 2010 arrived, and is expected to improve further. Also, the thermodynamic 

efficiency of R-410A is not as high as that of HCFC-22 at operating conditions typical for rating 

of room air conditioner performance. 

Scroll compressors require high precision to produce their internal components and are 

typically found in higher-efficiency central air-conditioning systems. Scroll compressors 

compress gas in a fundamentally different manner from traditional compressors — between two 

spirals, one fixed and one orbiting. Scroll compressors EERs for HCFC-22 refrigerant range 

from 10.8 to 11.2 for the capacities of interest for larger room air conditioners. Scroll 

compressors are generally 1 to 2 inches taller than rotary compressors, and therefore are better 

suited for larger units.84 Scroll compressors can be larger and heavier than their rotary 

counterparts. Thus, incorporating these compressors may require larger chassis sizes and bracing 

to accommodate the increased size and weight. 

Switching Power Supplies 

A potential area for standby power improvement for room air conditioners is the power 

supply on the control board. As with clothes dryers, a typical room air conditioner may use an 

unregulated plus regulated control board power supply, with voltage regulators stepping down 

the unregulated voltage(s) to the level(s) required by the control logic, display, and remote 

control sensor. As noted previously for clothes dryers, this approach results in a rugged power 

supply which is reliable, but typically has an efficiency of about 55 percent. The power supply 

accounts for the majority of the energy consumed by the control board in inactive mode. DOE’s 

room air conditioner reverse engineering showed that the majority of the inspected units used 

this type of power supply. 

Power supply efficiency may be improved, at higher cost and complexity, with the use of 

switching power supplies. For a complete discussion of switching power supply function and 

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efficiency, see section 3.15.2.1 for the comparable clothes dryer technology option. Based on 

DOE’s reverse engineering, described in chapter 5 of this TSD, DOE determined that room air 

conditioners with switching power supplies consume approximately 0.7 W in standby mode, a 

roughly 50 percent power savings as compared with standby power consumption with linear 

power supplies. 

Two-speed, variable-speed, or modulating-capacity compressors 

Most conventional single speed compressors run at a constant speed and vary their 

capacity by cycling on and off in response to the thermostat. The efficiency of systems using 

these compressors is typically lower than full-capacity efficiency at part load, due to off-cycle 

losses. Variable-speed compressors are typically implemented through the use of an electronic 

control that varies the input frequency of the power supply for the compressor motor. Variablespeed compressors enable modulation of the refrigeration-system cooling capacity, allowing the 

air conditioner to match the cooling load. This can improve efficiency by eliminating off-cycle 

losses and because, when operating with the lower mass flow at part load, the heat exchangers 

are more effective. There are non-energy advantages to variable-speed control, including quieter 

operation at low speeds, enhanced comfort by eliminating temperature fluctuations in the room, 

and potential for improved dehumidification. 

The control of variable-speed compressors is accomplished through the use of electronic 

adjustable-speed drives (ASDs) at the motor. Because electronic ASDs require no drive-train in 

order to be coupled to the motor, they can be used with the sealed refrigeration systems used in 

room air conditioners. ASDs can be designed for use with induction motors or with permanentmagnet brushless motors. There are two inverter types that are applicable to induction motors 

typically used in room air conditioner compressors: voltage source (VSI) and pulse-width 

modulated voltage source (PWM) inverters. In either case, the input AC power supply is first 

converted to DC by using a solid-state rectifier. This DC signal is then converted to a variablefrequency AC waveform by the inverter and supplied to the motor. The speed of the motor is 

roughly proportional to the frequency.85 

A recently developed method for modulating capacity in scroll compressors is 

intermittent discharge. This technology utilizes a pressure control system in which a solenoid 

valve opens, relieving the pressure on the back side of a piston. This spring-loaded piston is 

connected to the rotating scroll, and the scroll-piston system is then displaced once the 

backpressure is removed. This displacement disengages the scrolls, leaving the driveshaft free to 

rotate without any compression taking place. Modulating the time in which the scrolls are 

engaged allows capacity to be varied from 10 to 100 percent of maximum. Intermittent discharge 

technology, however, is only applicable to scroll compressors, and is a proprietary approach. r 

There are no obvious technical barriers to use of variable-speed compressors in room air 

conditioners. ASDs have been demonstrated to perform well with both rotary and scroll 

compressors. The heat pump market in Japan is now dominated by split systems equipped with 

r

 For more information, please visit www.digitalscroll.com/digitalweb/english/howitworks.htm 

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variable-speed rotary compressors. Based on an initial US market survey, a number of 

manufacturers offer split system air conditioners equipped with inverter systems using variable 

speed compressors. The most common motor used in this application is an induction motor. But 

the HVAC industry is now showing a strong interest in brushless permanent magnet motors due 

to their high efficiency. 

As stated earlier, technology options that primarily improve efficiency on a seasonal 

basis will not demonstrate any efficiency improvements according to the current DOE test 

procedure which specified steady-state conditions. The greatest benefit of variable speed systems 

is to save energy on a seasonal basis. Because tests have not been performed to determine the 

amount of cycling in room air-conditioners, the potential magnitude of seasonal energy savings 

in room air units is not well understood. Research has demonstrated that energy savings from 15 

to 40 percent are attainable in central air conditioning systems.86,87,88 In the previous rulemaking, 

DOE estimated that the implementation of variable-speed compressors in room air-conditioners 

could achieve an energy savings of approximately 10 percent.89 However, comments received 

from manufacturers subsequent to the Framework Document public meeting of this current 

rulemaking indicate that room air conditioners are typically purchased oversized relative to the 

conditioned space, indicating that they would operate in on/off mode and thus preclude the 

energy savings associated with variable-speed systems. 

Thermostatic or electronic expansion valves 

Manufacturer interviews and DOE’s reverse engineering indicate that the capillary tube is 

the flow control device that is currently used by all room air conditioners. The capillary tube is a 

pressure-reducing device that consists of a small-diameter tube that connects the outlet of the 

condenser to the inlet of the evaporator. The very high pressure drop as refrigerant flows through 

the capillary allows the high and low pressures in the system to be maintained. Since it is a fixed 

device, the capillary tube provides optimum system operating parameters over a narrow range of 

operating conditions. 

The thermostatic expansion valve (TXV) — a flow-control alternative to the capillary 

tube — is commonly used in higher-efficiency central air-conditioning systems. TXVs regulate 

the flow of liquid refrigerant entering the evaporator in response to the superheat of the 

refrigerant leaving it. TXVs can adapt better to changes in operating conditions, such as those 

due to variations in ambient temperature, which affect the condensing temperature. As a result, 

TXVs can control for optimum system operating parameters over a wider range of operating 

conditions, and can thus improve seasonal efficiency. 

Electronic expansion valves (EEVs) are similar to TXVs, but they operate using 

electronic (microprocessor) control. The EEV uses a pulse motor, which rotates based on an 

electronic signal from a microcomputer determining the desired valve position from measured 

system parameters. While a TXV is limited due to its thermo-mechanical design, there is greater 

flexibility for operation of an EEV. Research has demonstrated that, when incorporated into airconditioning systems using inverter-driven variable-speed compressors, EEVs improve seasonal 

energy efficiency beyond that of systems using conventional TXVs. As with variable speed 

compressors, the main benefit of electronic expansion valves is to improve efficiency on a 

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seasonal basis. DOE is aware of a patent describing a room air conditioner using an electronic 

expansion valve90 but is not aware of any publications describing prototype testing to evaluate 

the efficiency improvement potential of this technology. 

Thermostatic cyclic controls 

Remote thermostatic cyclic controls more accurately monitor room temperature than 

typical built-in thermostats. Research has been conducted to investigate the use of fuzzy logic 

controllers for HVAC applications. These controller types have been shown to improve the 

performance of HVAC systems over that of conventional controllers. Thermostatic controls 

could offer seasonal energy savings. 

As with variable speed compressors and expansion valves, the DOE test procedure can 

only measure energy efficiency improvements based on steady-state conditions. In addition, no 

data were found or presented that indicated how the performance of room air conditioners could 

be enhanced with thermostatic cyclic controls. 

Technologies Not Passed to the Screening Analysis 

DOE identified the following technologies as potentially providing opportunity for 

energy savings. However, as described individually for each of the technologies, DOE 

determined that these technologies were not suitable for consideration for the engineering 

analysis because sufficient data are not available to demonstrate that the technologies save 

energy as compared to current products. 

R-407C Refrigerant 

R-407C is a blend of HFC refrigerants that could be considered for use in room air 

conditioners instead of R-410A. In response to stakeholder comments during the preliminary 

analysis phase, DOE conducted preliminary modeling of R-407C room air conditioner systems, 

using the MarkN analysis tool used for energy modeling.s 

DOE conducted this R-407C assessment using five room air conditioner energy models 

developed as part of the engineering analysis. These energy models represent product classes 1, 

3, and 5, all product classes with louvered sides and without reverse cycle, with varying 

capacities (5,000 Btu/h, 8,000 Btu/h, 12,000 Btu/h, 24,000 Btu/h, and 28,000 Btu/h). The 

development of energy models for these products is described in section 5.9.2.4 in chapter 5 of 

the TSD. DOE compared identical designs for these products, operating with both R-410A and 

R-407C. These designs represent drop-in of R-410A and/or R-407C in a product designed for 

HCFC-22. Figure 3.15.2 shows the modeling results of R-410A and R-407C with the MarkN 

model. In each product class, the efficiency of the R-407C system was notably lower than the 

s

 The MarkN energy model is discussed in chapter 5, “Engineering Analysis”, of the TSD, in section 5.9.2.4. 

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respective R-410A system. These analyses don’t definitively indicate that R-407C could not 

provide any efficiency benefit as compared to R-410A, because the systems were optimized for 

neither of these refrigerants for this analysis. However, they do provide an indication that R407C does not provide clear improvement. 

0 

2 

4 

6 

8 

10 

12 

Product Class 5 ­

EER (Btu/h/W) 

R-410A Modelling 

R-407C Modelling 

Product Class 1 Product Class 3 - Product Class 3 - Product Class 5 ­

8,000 Btu/h 12,000 Btu/h 24,000 Btu/h 28,000 Btu/h 

Figure 3.15.2. Modeling of R-407C compared to R-410A 

The room air conditioning industry has switched to R-410A in response to EPA 

requirements banning use of HCFC-22 starting in 2010. 74 FR 66412, 66418 (December 15, 

2009). Based on discussions with manufacturers during both preliminary analysis and final rule 

phase interviews, there was no indication that any manufacturers would instead consider use of 

R-407C refrigerant as a potentially more efficient option. DOE concluded that it is not realistic to 

expect the industry to transition away from R-410A in response to more stringent efficiency 

standards. Hence, DOE’s analysis was based on industry’s continued use of R-410A, and 

alternatives such as R-407C were not considered as design options. 

Liquid-Line to Suction-Line Heat Exchangers 

In response to stakeholder comments during the preliminary analysis phase, DOE 

investigated the use of suction-line heat exchangers (SLHX). These heat exchangers cool the 

refrigerant leaving the condenser (or leaving the subcooler, if the refrigeration circuit has a 

subcooler) by simultaneously warming the refrigerant vapor leaving the evaporator. This 

increases capacity, but also increases compressor power input, since the warmer refrigerant 

vapor returning to the compressor has greater volume. However, for some refrigerants, the 

technology can improve efficiency. 

3-85 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The preliminary phase comments of the California Investor-Owned Utilities (IOUs) cited 

a study conducted by the National Institute of Standards and Technology (NIST) investigating 

the use of LSHX.t This study reports an EER improvement using a SLHX of 1.0 percent for an 

outdoor temperature of 95 °F, which is used in the DOE energy test. These results were obtained 

in a modeling study using the NIST vapor-compression model CYCLE 11. There is no indication 

in the paper that the simulations address room air conditioners, since it does not mention outdoor 

air moisture content, which would be an important parameter affecting performance of room air 

conditioners. While the simulations show a potential for slight performance improvement, 

questions about the applicability of the assessment remain, because it is not clear that the 

simulations are applicable for room air conditioners and the because the results were not 

validated experimentally. 

DOE notes that use of SLHX raises the temperatures of the incoming vapor to the 

compressor, which raises the temperature of the compressor. Warmer compressor temperature 

will generally reduce compressor lifetime, since heat-sensitive compressor components are 

designed for specified life when operating under specific conditions. Compressor suction 

temperatures are typically close to 65  ̊F in room air conditioners operating under DOE test 

conditions. This is also typically the highest allowable steady-operating suction temperature for 

R-410A rotary compressors, based on compressor specifications obtained from compressor 

vendors. A SLHX operating at close to 50% effectiveness (as analyzed in the NIST study) would 

raise suction temperature roughly 20  ̊F, thus significantly exceeding the specified limit. 

During interviews conducted during the preliminary and final rule analysis, 

manufacturers did not indicate that SLHX could be used to improve system performance. 

Because of concerns regarding impacts on product life and reliability, and the fact that 

manufacturers did not indicate that this technology can be used to improve efficiency, DOE did 

not consider SLHX as a design option in its engineering analysis. 

3.15.3 Energy Efficiency 

In preparation for the screening and engineering analyses, DOE gathered data on the 

energy efficiency of residential clothes dryers and room air conditioners currently available in 

the marketplace. This data is taken from databases maintained by a variety of regulatory 

agencies. While this section is not intended to provide a complete characterization of the energy 

efficiency of all appliances currently available and in use, it does provide an overview of the 

energy efficiency of each product covered by this rulemaking. 

t “Performance of R-22 and its Alternatives Working at High Outdoor Temperatures.” Eighth International Refrigeration 

Conference at Purdue University, West Lafayette, IN – July 25-28, 2000 pp. 47-54 

3-86 

 

 

 

 

 

 

 

 

3.15.3.1 Residential Clothes Dryers 

The CEC publishes a list of “certified” residential clothes dryers. Figure 3.15.3 through 

Figure 3.15.5 display the distribution of clothes dryers in the CEC database that are currently 

available on the market as a function of EF for electric standard and compact dryers, gas dryers. 

Each graph also shows the current federal energy conservation standard. All of the dryer models 

listed in the CEC database meet or are above the current standard level, if one exists for the 

product class. There are also no ventless clothes dryer models listed in the CEC database since 

there is no accepted way of rating the performance of such dryers. 

Figure 3.15.3 Electric Standard Capacity Clothes Dryers in the CEC Directory91 

3-87 

 

Figure 3.15.4 Electric Compact Capacity Clothes Dryers in the CEC Directory92 

3-88
 
 

 

 

 

 

 

Figure 3.15.5 Gas Clothes Dryers in the CEC Directory93 

AHAM submitted market share efficiency data for residential clothes dryers. Table 3.15.4 

and Table 3.15.5 present the market share efficiency data for electric standard and gas dryers, 

respectively. AHAM noted that, in order to maintain confidentiality, market share for electric 

standard dryers between EF of 3.20 and 3.29 were incorporated into the EF range between 3.10 

and 3.19. Similarly, market share for gas clothes dryers with an EF > 2.94 was incorporated into 

the EF > 2.85 efficiency bin. 

Table 3.15.4 Residential Clothes Dryer Market Share Efficiency Data for Electric Standard 

Dryers94 

EF Market Share (%) 

2005 2006 

3.01 – 3.09 26 33 

3.10 – 3.29 74 67 

Table 3.15.5 Residential Clothes Dryer Market Share Efficiency Data for Gas Dryers95 

EF Market Share (%) 

2005 2006 

2.67 – 2.74 25 28 

2.75 – 2.84 42 44 

> 2.85 32 27 

3-89
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

3.15.3.2 Room Air Conditioners 

Although not completely representative of the entire current room air conditioner market, 

CEC, ENERGY STARu and AHAM publish lists of “certified” room air conditioners. The 

AHAM Room Air Conditioner Certification Program verifies the cooling and heating capacity 

rating, amperes, and EER of each listed room air conditioner as tested by an independent 

laboratory.v

 DOE consolidated the three databases and reviewed all of the listed room air 

conditioners, searching websites of the manufacturers and retailers to verify whether the products 

are still active. DOE conducted this investigation in August 2008. 

Figure 3.15.6 through Figure 3.15.9 show the EER versus the capacity of each room air 

conditioner listed in the consolidated database. Each graph illustrates the current federal energy 

conservation standard, which became effective on October 1, 2000. The screening of products 

which are no longer available removed many old products, but some of the products still had 

reported EER below the current federal standards. These may have erroneous EER listings, or 

have model numbers identical to updated products. In any case the exhaustive screening of the 

products in the databases clearly was not sufficiently thorough to eliminate all outdated entries. 

u

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

v

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

3-90 

 

 

Figure 3.15.6 CEC, AHAM, and ENERGY STAR Certified Room Air Conditioners
 

without Reverse Cycle and with Louvered Sides (Product Classes 1–5) 96, 97, 98
 

3-91 

 

Figure 3.15.7 CEC, AHAM, and ENERGY STAR Certified Room Air Conditioners
 

without Reverse Cycle and without Louvered Sides (Product Classes 6–10)99, 100, 101
 

3-92 

Figure 3.15.8 CEC, AHAM, and ENERGY STAR Certified Room Air Conditioners with
 

Reverse Cycle (Product Classes 11–14)102, 103, 104
 

3-93 

 

 

 

 

 

 

 

 

Figure 3.15.9 CEC, AHAM, and ENERGY STAR Certified Room Air Conditioners
 

Casement-Only and Casement-Slider (Product Classes 15, 16) 105, 106, 107
 

Figure 3.15.10 shows the distribution of the models listed in the screened database for 

each product class. Nearly 70 percent of the products are room air conditioner models without 

reverse cycle and with louvered sides (product classes 1 through 5). In addition, there are a high 

number of models in product class 8, room air conditioners without reverse cycle, without 

louvered sides, and a capacity between 8,000 and 13,999 Btu/h. Also of note, there are no 

models in product class 13 (with reverse cycle, with louvered sides, capacity greater than 

120,000 Btu/h). During individual manufacturer interviews, manufacturers confirmed that 

product classes 1, 2, 3, 4, 5, and 8 make up the vast majority of room air conditioner shipments. 

3-94 

 

 

 

 

 

 

 

 

 

Figure 3.15.10 Distribution of Room Air Conditioner Models in the CEC, AHAM, and
 

ENERGY STAR Databases108, 109, 110
 

DOE during the final rule phase conducted another investigation of the ENERGY-STAR 

Database, manufacturer websites, and vendor websites to assemble information on newly 

available R-410A units. Figure 3.15.11 through Figure 3.15.12 show the EER versus the 

capacity of each room air conditioner found in this investigation. Each graph illustrates the 

current federal energy conservation standard, which became effective on October 1, 2000. Some 

of the products still had reported EER below the current federal standards. These may have 

erroneous EER listings, are mislabeled, or have model numbers identical to updated products. 

DOE completed this investigation in May 2010. 

3-95 

 

8 

8.5 

9 

9.5 

10 

10.5 

11 

11.5 

12 

12.5 

0 5000 10000 15000 20000 25000 30000 35000 40000 

EER (Btu/hr/W) 

Capacity (Btu/hr) 

R-410A Units 

DOE Minimum Federal Standard 

Figure 3.15.11. R-410A Room Air Conditioners without Reverse Cycle and with Louvered
 

Sides (Product Classes 1–5)
 

3-96 

 

 

 

 

 

 

 

 

 

 

 

 

 

8 

8.2 

8.4 

8.6 

8.8 

9 

9.2 

9.4 

9.6 

9.8 

10 

5000 7000 9000 11000 13000 15000 

EER (Btu/h/W) 

Capacity (Btu/hr) 

R-410A Units 

DOE Minimum Federal Standard 

Figure 3.15.12. R-410A Room Air Conditioners without Reverse Cycle and with Louvered 

Sides (Product Classes 1–5) 

Investigation of Max-Tech Units 

During the preliminary analysis public meeting, DOE requested comment on the 

efficiency levels chosen by DOE. DOE identified products with an EER of 12.0 as the highest 

efficiency products available on the market. Several stakeholders commented that DOE should 

update its analysis to include all current ENERGY STAR and max-tech units on the market. In 

particular, stakeholders indicated that the CEC and the ENERY-STAR databases listed products 

with higher efficiency levels than those considered by DOE. 

DOE is aware that the ENERGY STAR and CEC databases have listed products that 

exceed the max-tech EER of 12.0 that DOE identified in the preliminary analysis. Table 3.15.6 

below, shows products listed at 12.0 EER or higher in one or both of these databases. Some of 

these products were noted specifically in stakeholder comments. 

Table 3.15.6 RAC Models of Interest for Max-Tech Analysis, as Listed in the ENERGYSTAR and CEC Listings 

Brand Model Listed EER Source 

3-97 

 

 

 

 

 

 

 

 

 

CEC ENERGY STAR 

Climette CH1826A 13.8 �

Comfort-Aire REC-183 13.8 �

Fedders AED18E7DG 13.8 �

Maytag MED18E7A 13.8 �

Fedders A7Q06F2A 13.4 �

Turbo Air TAS-09EH 13.5 �

Turbo Air TAS-12EH 13.0 �

Turbo Air TAS-18EH 13.0 �

Friedrich SS10M10 12.0 � �

Friedrich YS09L10 12.0 � �

Friedrich SS10L10 12.0 � �

Friedrich XQ06M10 12.0 � �

Friedrich SS12M10 12.0 �

Haier ESAD4066 12.0 �

DOE investigation of these products indicates that none of the products listed with EER 

higher than 12.0 represent valid RAC ratings, and that some of the products rated at an EER of 

12.0 are also invalid representations. The first five products in the table are listed with much 

lower EER ratings in Natural Resources Canada (NRCan) databasew. Table 3.15.7 below 

contains the NRCan ratings of these products. 

Table 3.15.7 Selected Product Ratings in NRCan Directory 

Brand Model No. Listed EER in 

NRCan Database 

Climette CH1826A 9.7 

Comfort-Aire REC-183 9.7 

Fedders AED18E7DG 9.8 

Maytag MED18E7A 9.8 

Fedders A7Q06F2A 10.7 

The three Turbo-Air products are ductless mini-split products (as identified by the 

manufacturer’s websitex

), not room air conditioners. The Friedrich SS12M10 has been rerated at 

w (1) “EnerGuide for Equipment – EnerGuide Room Air Conditioner Directory 2002”. Natural Resources Canada, 

Office of Energy Efficiency.2002; (2) Room Air Conditioner Model Listing. “EnerGuide Room Air Conditioner 

Directory 2004” http://oee.nrcan.gc.ca/. 

x

 Product Specifications and Descriptions for Turbo Air Products TAS-09EH, TAS-12EH, TAS-18EH. Please see 

more information at www.turboairinc.net/productspecs/productspecs.html 

3-98 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

lower than 12.0 EERy, and the validity of the 12.0 rating of the Haier ESAD4066 is also in 

question. 

In particular, Consumer Reports published an article in October 2008z

 in which it 

reported on test results indicating that the Haier ESAD4066’s efficiency was not 12 EER. 

DOE’s analysis of this unit using the Mark N energy model (discussed in chapter 5 of this TSD), 

showed that matching this performance level with the energy model required making some input 

assumptions that DOE considers unlikely, particularly for the condenser air flow rate. 

Consequently, DOE concludes that its identification of a ma- tech available level no 

higher than 12.0 EER is valid, given the information available. 

REFERENCES 

1 “32nd Annual Portrait of the U.S. Appliance Industry: The Share-of-Market Picture for 

2008.” Appliance Magazine, September 2009. 

2 Ibid. 

3 Ibid. 

4 “Annual Portrait of the U.S. Appliance Industry: The Share-of-Market Picture.” 

Appliance Magazine, September 2005–2009. 

5 Ibid. 

6 Appliance Magazine, September 2009. Op. cit. 

7 Appliance Magazine, September 2005–2009. Op. cit. 

8 Appliance Magazine, September 2009. Op. cit. 

9 Maytag. 2005. “Whirlpool Corporation and Maytag Corporation Sign Definitive Merger 

Agreement.” Maytag Press Release, August 22, 2005. 

10 P. Hussmann. 2006. “Justice to Extend Maytag-Whirlpool Merger Review.” Newton 

Daily News Online. February 14, 2006. 

y

 Friedrich product specifications. Specifications for SS12M10. Please see more information at 

http://kuhl.friedrich.com/model-specifications/ 

z

 Consumer Reports. October 2008. Pg. 24 Vol. 73 No. 10. Copyright 2008 Consumers Union of U.S., Inc. 

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11 W. Ryberg. 2006. “Harkin, Boswell want Maytag sale blocked.” Des Moines Register. 

January 13, 2006. 

12 Ibid. 

13 U.S. Department of Justice (U.S. DOJ). 2006. Department of Justice Antitrust Division 

Statement on the Closing of its Investigation of Whirlpool’s Acquisition of Maytag. 

March 29, 2006. 

14 Ibid. 

15 Association of Home Appliance Manufacturers (AHAM) Fact Book 2005. 

16 Ibid. 

17 AHAM Fact Book 2003. 

18 CEEE. 2000. National Residential Home Appliance Market Transformation Strategic 

Plan. December, 2000. 

19 Tiele, Simone. 2008. “Australia’s Approach to Standby Power.” In Reports of national 

standby power consumption and targeted policies. New Delhi, India, April 2. Department 

of the Environment, Water, Heritage and the Arts, Australia. Available online at: 

www.iea.org/textbase/work/workshopdetail.asp?WS_ID=352. (Last accessed on August 

28, 2008.) 

20 Database of State Incentives for Renewables & Efficiency. Incentives for Clothes 

Washers/Dryers. 2008. Available online at: www.dsireusa.org. (Last accessed on 

September 22, 2008) 

21 U.S. Census Bureau. New Privately Owned Housing Units Started in the United States by 

Purpose and Design. 2009. 

22 Ibid. 

23 AHAM. 2008. Residential Clothes Dryer Shipments. August 20, 2008. Docket No. 

EERE-2007-BT-STD-0010, Comment Number 15. 

24 AHAM Fact Book 2003 and 2005. 

25 ENERGY STAR. Room Air Conditioners 2007 Product Snapshot. Prepared by D&R 

International, Ltd. on behalf of the U.S. Department of Energy. 2007. Available online at: 

www.energystar.gov/index.cfm?c=manuf_res.pt_appliances (Last accessed on April 21, 

2009.) 

3-100 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

26 AHAM Fact Book 2005. 

27 U.S. Census Bureau. Annual Survey of Manufacturers (ASM): Value of Product 

Shipments: Value of Shipments in Product Classes. 1994-2008, issued annually. 

28 Ibid. 

29 AHAM Fact Book 2003. 

30 AHAM. Import/Export Trade Report – December 2009. 2010. 

31 Ibid. 

32 Ibid. 

33 Ibid. 

34 AHAM Fact Book 2005. 

35 Ibid. 

36 AHAM Fact Book 2003 and 2005. 

37 U.S. Census Bureau. ASM: General Statistics: Statistics for Industry Groups and 

Industries. 1996–2008, issued annually. 

38 Ibid. 

39 Ibid. 

40 Ibid. 

41 Ibid. 

42 Ibid. 

43 Ibid. 

44 Ibid. 

45 Ibid. 

46 U.S. Census Bureau. Survey of Plant Capacity. 2004–2005, issued annually. 

3-101 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

47 http://www.friedrich.com/products/ModelDocuments.php?model=CP10E10 

48	 P. Pescatore and P. Carbone. 2005. High Efficiency High Performance Clothes Dryer. 

Final Report to Department of Energy. 

49 T Richter. Energy Efficient Laundry Process. 2005. GE Global Research, Final Project 

Report for the Department of Energy, DOE Award DE-FC26-01NT41261. 

50 Consumer Energy Center. Clothes Dryers – Buying Smart. 2008. Available online at: 

www.consumerenergycenter.org/home/appliances/dryers.html (Last accessed on October 

1, 2008.) 

51 Science Applications, Inc. Energy Efficiency Program for Clothes Washers, Clothes 

Dryers and Dishwashers. 1977. SAI-77-839, La Jolla, CA. 

52 D. Hekmat and W.J. Fisk. 1983. Improving the Energy Efficiency of Residential Clothes 

Dryers. Lawrence Berkeley Laboratory, LBL-16813 ,July 1983. 

53 D.F. Joslin. 1996. Reversing Clothes Dryer and Method Therefor. U.S. Patent No. 

5,555,645, issued September 17, 1996. 

54 T. Richter. 2005. Op. cit. 

55 George Wilkenfeld and Associates Pty. Ltd. and Lawrence Berkeley Laboratory. 1993. 

Benefits and Costs of Implementing Minimum Energy Performance Standards for 

Household Electrical Appliances in Australia. Final Report Prepared for State Electricity 

Commission of Victoria, July, p. 138. 

56 D. Hekmat and W.J. Fisk. 1983. Op. cit. 

57 National Institute of Standards and Technology. Appliance Energy Efficiency 

Improvement Target for Clothes Dryers. 1977. 

58	 Ibid. 

59 P.K. Bansal, J.E. Braun, and E.A. Groll. 2001. “Improving the Energy Efficiency of 

Conventional Tumbler Clothes Drying Systems.” International Journal of Energy 

Research, Vol. 25, January 2001, pp. 1315–32. 

60 L. Palandre and D. Clodic. 2003. “Comparison of Heat Pump Dryer and Mechanical 

Steam Compression Dryer.” Presented at the International Congress of Refrigeration. 

Washington, D.C. Ecoles des Mines de Paris, Center for Energy Studies, 

3-102 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

61 E. Bush and J. Nipkow. 2006. Tests and Promotion of Energy-Efficient Heat Pump 

Dryers. Report Prepared for International Energy Efficiency in Domestic Appliances & 

Lighting Conference ’06. 

62 Ibid. 

63 P. Pescatore and P. Carbone. 2005. Op. cit. 

64 Ibid. 

65 Ibid. 

66 Ashley, Steven. 1998. “Energy-Efficient Appliances.” Mechanical Engineering. Vol. 

120, No. 3, pp. 94–97. 

67 Ibid. 

68 J. Gerling. 2003. “Microwave Clothes Drying – Technical Solutions to Fundamental 

Challenges.” Appliance Magazine. April 2003. 

69 Ibid. 

70 P. Pescatore and P. Carbone. 2005. Op. cit. 

71 Ibid. 

72 Ibid. 

73 Ibid. 

74 George Wilkenfeld and Associates Pty. Ltd. 2007. Extending the Water Efficiency 

Labelling and Standards (WELS) Scheme to Washer/Dryers and Condenser Dryers. 

Report Prepared for the Department of the Environment and Water Resources, pp. 3–5. 

75 “’Green’ Clothes Dryer Technology to Launch at Builders’ Show.” Appliance Magazine 

– Daily News. 2008. 

76 M.H. Kim and C.W. Bullard. 2002. “Performance Evaluation of a Window Room Air 

Conditioner with Microchannel Condensers.” Journal of Energy Resources Technology. 

Vol. 124, Issue 1, pp. 47–55. 

77 D. Fridley, G. Rosenquist, J. Lin, L. Aixian, X. Dingguo, and C. Jianhong. 2006. 

Technical and Economic Analysis of Energy Efficiency of Chinese Room Air 

3-103 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Conditioners. Lawrence Berkeley National Laboratory, China National Institute of 

Standardization, and Beijing Energy Efficiency Center, LBNL-45550. 

78 J. Adnot. 1999. Energy Efficiency of Room Air-Conditioners (EERAC). DirectorateGeneral for Energy (DGXVII) of the European Communities, p. 60. 

79 L.M. Schlager, M.B. Pate, and A.E. Bergles. 1990. “Performance Predictions of 

Refrigerant-Oil Mixtures in Smooth and Internally Finned Tubes - Part II: Design 

Equations.” ASHRAE Transactions. 96(1): pp 170–182. 

80	 Mimakim M. 1987. “Effectiveness of Finned-Tube Heat Exchanger Coated HydrophilicType Film”, ASHRAE Transactions, 93(1): pp 62-71. 

81 M.H. Kim and C. Bullard. 2002. Op. cit. 

82 U.S. DOE. 1997. Op. cit. 

83 Simmons. 2003. Op. cit. 

84 ENERGY STAR. 2003. Expansion of ENERGY STAR Room Air-Conditioner Criteria to 

Include Through-the-Wall Units. D&R International, Ltd. 

85 U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. 

Technical Support Document for Energy Conservation Standards for Room Air 

Conditioners, September 1997. Washington, D.C. Available online at: 

www.eere.energy.gov/buildings/appliance_standards/residential/room_ac.html 

86 H.I. Henderson, Jr. 1990. “A Side-by-Side Field Test of Variable-Speed and ConstantSpeed Air Conditioners.” ASHRAE Transactions. 96(1): pp 683–692. 

87 V. Bahel and S.M. Zubair. 1989. “An Assessment of Inverter-Driven Variable-Speed Air 

Conditioners: Sample Performance Comparison with a Conventional System.” ASHRAE 

Transactions. 95(1): pp 455–464. 

88	 M. Hori, I. Akamine, and T. Sakai. 1985. “Seasonal Efficiencies of Residential Heat 

Pump Air Conditioners with Inverter-Driven Compressors.” ASHRAE Transactions. 

91(2B): pp. 1585–1595. 

89	 Ibid. 

90	 Tezuka, T., K. Isono, “Room Air Conditioner”, U.S. Patent 4,795,089, Assignee 

Mitsubishi Denki Kabushiki Kaisha, January 3, 1989. 

91 CEC Appliance Efficiency Database. April 2009. Available online at: 

www.energy.ca.gov/appliances/database/ (Last accessed on April 3, 2009.) 

3-104 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

92 Ibid. 

93 Ibid. 

94 AHAM. 2008. De-identified Clothes Dryer Data – Collected December 2007 for DOE 

Rulemaking. Updated 4/11/2008. April 11, 2008. Docket No. EERE-2007-BT-STD-0010, 

Comment Number 14. 

95 Ibid. 

96 CEC Appliance Efficiency Database. 2008 Op. cit. 

97 ENERGY STAR Room Air Conditioner Database. May 2008. Available online at: 

www.energystar.gov/index.cfm?c=roomac.pr_room_ac (Last accessed on May 9, 2008). 

98 AHAM Certified Product Listing - Room Air Conditioners. May 2008. Available online 

at: http://207.140.180.12/dirsvc/aham.nsf/fraMain?OpenFrameset (Last accessed on May 

9, 2008.) 

99 CEC Appliance Efficiency Database. 2008 Op. cit. 

100 ENERGY STAR Room Air Conditioner Database. Op. cit. 

101 AHAM Certified Product Listing - Room Air Conditioners. May 2008. Op. cit. 

102 CEC Appliance Efficiency Database. Op. cit. 

103 ENERGY STAR Room Air Conditioner Database. Op. cit. 

104 AHAM Certified Product Listing - Room Air Conditioners. May 2008. Op. cit. 

105 CEC Appliance Efficiency Database. Op. cit. 

106 ENERGY STAR Room Air Conditioner Database. Op. cit. 

107 AHAM Certified Product Listing - Room Air Conditioners. May 2008. Op. cit. 

108 CEC Appliance Efficiency Database. Op. cit. 

109 Energy Star Room Air Conditioner Database. Op. cit. 

110 AHAM Certified Product Listing - Room Air Conditioners. May 2008. Op. cit. 

3-105