5-i

CHAPTER 5. ENGINEERING ANALYSIS

TABLE OF CONTENTS

5.1 INTRODUCTION ........................................................................................................... 5-1

5.2 TECHNOLOGIES UNABLE TO BE INCLUDED IN THE ANALYSIS ..................... 5-2

5.3 PRODUCT CLASSES ANALYZED.............................................................................. 5-2

5.4 EFFICIENCY LEVELS................................................................................................... 5-3

5.4.1 Efficiency Metrics............................................................................................................ 5-3

5.4.2 Appendix J1/Appendix J2 Efficiency Metric Translations.............................................. 5-5

5.4.3 Baseline Units.................................................................................................................. 5-6

5.4.4 Higher Efficiency Levels................................................................................................. 5-6

5.4.5 Maximum Technologically Feasible Efficiency Levels.................................................. 5-7

5.5 METHODOLOGY OVERVIEW.................................................................................... 5-7

5.5.1 AHAM Data Request....................................................................................................... 5-7

5.5.2 Product Testing Methodology.......................................................................................... 5-8

5.5.3 Product Teardown Methodology ..................................................................................... 5-8

5.5.3.1 Selection of Units...........................................................................................5-9

5.5.3.2 Generation of Bill of Materials......................................................................5-9

5.5.3.3 Cost Structure of the Spreadsheet Models.....................................................5-9

5.5.3.4 Cost Model and Definitions.........................................................................5-11

5.5.3.5 Cost Model Assumptions.............................................................................5-12

5.5.4 Manufacturer Interviews................................................................................................ 5-12

5.6 ANALYSIS AND RESULTS........................................................................................ 5-12

5.6.1 AHAM Data................................................................................................................... 5-12

5.6.2 Product Testing Results ................................................................................................. 5-12

5.6.2.1 Active Mode Testing....................................................................................5-14

5.6.2.2 Standby Mode and Off Mode Power ...........................................................5-18

5.6.2.3 Cleaning Performance Testing.....................................................................5-19

5.6.3 Product Teardowns ........................................................................................................ 5-33

5.6.3.1 Top-Loading Commercial Clothes Washers................................................5-33

5.6.3.2 Front-Loading Commercial Clothes Washers .............................................5-36

5.6.4 Cost-Efficiency Curves.................................................................................................. 5-40

5.6.4.1 Top-Loading Cost-Efficiency Curves..........................................................5-40

5.6.4.2 Front-Loading Cost-Efficiency Curves........................................................5-41

LIST OF TABLES

Table 5.4.1 Revisions to the Clothes Washer Test Procedure that Significantly Affect 

Efficiency Metrics................................................................................................ 5-4

Table 5.4.2 Appendix J1 and Appendix J2 Efficiency Level Translations for Top-Loading 

CCWs................................................................................................................... 5-5
5-ii

Table 5.4.3 Appendix J1 and Appendix J2 Efficiency Level Translations for FrontLoading CCWs..................................................................................................... 5-6

Table 5.5.1 Major Manufacturing Processes ............................................................................. 5-10

Table 5.6.4 Top-Loading Commercial Clothes Washer Test Unit Features.............................. 5-13

Table 5.6.5 Front-Loading Commercial Clothes Washer Test Unit Features ........................... 5-14

Table 5.6.6 Commercial Clothes Washer Standby Power Measurements................................. 5-19

Table 5.6.7 Production Cost Distribution for Baseline Top-Loading CCW.............................. 5-34

Table 5.6.8 Materials Cost Distribution for Baseline Top-Loading CCW................................ 5-34

Table 5.6.9 Baseline Front-Load Clothes Washer Production Cost Distribution...................... 5-38

Table 5.6.10 Baseline Front-Load Clothes Washer Materials Cost Distribution ...................... 5-38

Table 5.6.11 Incremental Manufacturing Costs for Top-Loading CCWs Based on MEFJ2...... 5-40

Table 5.6.12 Incremental Manufacturing Costs for Front-Loading CCWs Based on MEFJ2.... 5-42

LIST OF FIGURES

Figure 5.5.1 Manufacturing Cost Assessment Stages................................................................ 5-10

Figure 5.6.1 Relationship Between Equivalent MEFJ2 (Appendix J2) and Rated MEF 

(Appendix J1) for Top-Loading CCWs............................................................. 5-15

Figure 5.6.2 Relationship Between Equivalent IWF (Appendix J2) and Rated WF 

(Appendix J1) for Top-Loading CCWs............................................................. 5-16

Figure 5.6.3 Relationship Between Equivalent MEFJ2 (Appendix J2) and Rated MEF 

(Appendix J1) for Front-Loading CCWs........................................................... 5-17

Figure 5.6.4 Relationship Between Equivalent IWF (Appendix J2) and Rated WF 

(Appendix J1) for Front-Loading CCWs........................................................... 5-18

Figure 5.6.5 AHAM Soil/Stain Test Strip ................................................................................. 5-21

Figure 5.6.6 Total Cleaning Score vs. Appendix J2 MEFJ2 Efficiency Level for TopLoading CCWs................................................................................................... 5-22

Figure 5.6.7 Total Cleaning Score vs. Appendix J2 IWF Efficiency Level for TopLoading CCWs................................................................................................... 5-23

Figure 5.6.8 Total Cleaning Score vs. Cycle Time for Top-Loading CCWs ............................ 5-23

Figure 5.6.9 Total Cleaning Score vs. Appendix J2 MEFJ2 Efficiency Level for FrontLoading CCWs................................................................................................... 5-24

Figure 5.6.10 Total Cleaning Score vs. Appendix J2 IWF Efficiency Level for FrontLoading CCWs................................................................................................... 5-24

Figure 5.6.11 Total Cleaning Score vs. Cycle Time for Front-Loading CCWs........................ 5-25

Figure 5.6.12 Rinse Score vs. Appendix J2 MEFJ2 Efficiency Level for Top-Loading 

CCWs................................................................................................................. 5-26

Figure 5.6.13 Rinse Score vs. Appendix J2 IWF Efficiency Level for Top-Loading 

CCWs................................................................................................................. 5-26

Figure 5.6.14 Rinse Score vs. Cycle Time for Top-Loading CCWs......................................... 5-27

Figure 5.6.15 Rinse Score vs. Appendix J2 MEFJ2 Efficiency Level for Front-Loading 

CCWs................................................................................................................. 5-28

Figure 5.6.16 Rinse Score vs. Appendix J2 IWF Efficiency Level for Front-Loading 

CCWs................................................................................................................. 5-28
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Figure 5.6.17 Rinse Score vs. Cycle Time for Front-Loading CCWs....................................... 5-29

Figure 5.6.18 Sand Removal Score vs. Appendix J2 MEFJ2 Efficiency Level for TopLoading CCWs................................................................................................... 5-30

Figure 5.6.19 Sand Removal Score vs. Appendix J2 IWF Efficiency Level for TopLoading CCWs................................................................................................... 5-31

Figure 5.6.20 Sand Removal Score vs. Appendix J2 MEFJ2 Efficiency Level for FrontLoading CCWs................................................................................................... 5-32

Figure 5.6.21 Sand Removal Score vs. Appendix J2 IWF Efficiency Level for FrontLoading CCWs................................................................................................... 5-32

Figure 5.6.22 Production Cost Distribution for Baseline Top-Loading CCW .......................... 5-34

Figure 5.6.23 Baseline Top-Load Standard Clothes Washer Materials Cost Distribution........ 5-34

Figure 5.6.24 Production Cost Distribution for Efficiency Level 1 Front-Loading 

Commercial Clothes Washer ............................................................................. 5-38

Figure 5.6.25 Materials Cost Distribution for Efficiency Level 1 Front-Loading 

Commercial Clothes Washer ............................................................................. 5-38

Figure 5.6.26 Cost-Efficiency Curve Based on MEFJ2 for Top-Loading Commercial 

Clothes Washer.................................................................................................. 5-40

Figure 5.6.27 Cost-Efficiency Curve Based on MEFJ2 for Front-Loading Commercial 

Clothes Washer.................................................................................................. 5-42
5-1

CHAPTER 5. ENGINEERING ANALYSIS

5.1 INTRODUCTION

After conducting the screening analysis, the U.S. Department of Energy (DOE) 

performed an engineering analysis based on the remaining design options. The purpose of the 

engineering analysis is to establish the relationship between the manufacturing production cost 

(MPC) and increased levels of efficiency for each class of products. This relationship serves as 

the basis for cost/benefit calculations in terms of individual consumers, manufacturers, and the 

nation. As part of the engineering analysis, DOE also tests a sample of products to determine 

how energy and water consumption varies with increased levels of efficiency.

The primary inputs to the engineering analysis are baseline information from the market 

and technology assessment (chapter 3 of this technical support document (TSD)) and technology 

options from the screening analysis (chapter 4). Additional inputs include cost and energy 

efficiency data, which DOE received from the Association of Home Appliance Manufacturers 

(AHAM), and which DOE qualified and supplemented through teardown analysis and 

manufacturer interviews. The primary output of the engineering analysis is a set of costefficiency curves.

DOE typically structures its engineering analysis around one of three methodologies, 

described as follows:

(1) Design-option approach, which provides the incremental costs of adding to a baseline 

model design options that will improve its efficiency;

(2) Efficiency-level approach, which provides the relative costs of achieving increases in 

energy efficiency levels, without regard to the particular design options used to achieve 

such increases; and

(3) Cost-assessment (or reverse-engineering) approach, which provides “bottom-up” 

manufacturing cost assessments for achieving various levels of increased efficiency, 

based on detailed data regarding costs for parts and material, labor, shipping/packaging, 

and investment for models that operate at particular efficiency levels.

DOE conducted the engineering analyses for the top-loading and front-loading product 

classes using a combination of the efficiency-level approach and cost-assessment approach. The 

cost-assessment approach provides an accurate means for estimating a single manufacturer’s 

incremental manufacturing costs for achieving various levels of increased efficiency. This 

approach involves physically disassembling commercially available products to develop costefficiency relationships for each manufacturer’s product lines. Because each manufacturer may 

choose a different path to achieve higher levels of efficiency, an efficiency-level approach 
5-2

produces an industry-wide cost-efficiency relationship for each product class. DOE developed 

cost-efficiency relationships for the top-loading and front-loading product classes by calculating 

the market-weighted average of the individual cost-efficiency relationships it developed for each 

manufacturer.

5.2 TECHNOLOGIES UNABLE TO BE INCLUDED IN THE ANALYSIS

In performing the engineering analysis, DOE did not consider for analysis certain 

technologies that met the screening criteria, described in chapter 4 of this TSD, but were unable 

to be evaluated for one or more of the following reasons: (1) data are not available to evaluate 

the energy efficiency characteristics of the technology; (2) available data suggested that the 

efficiency benefits of the technology would be negligible; or (3) certain technologies cannot be 

measured according to the conditions and methods specified in the DOE clothes washer test 

procedure (10 CFR 430, subpart B, appendix J2; hereafter, “appendix J2”).

As described in final rule notice, interested parties suggested adding temperaturedifferentiated pricing controls to the list of design options for consideration. Such controls would 

offer the potential to incentivize energy savings by providing favorable vend pricing for lowertemperature wash/rinse settings. DOE’s market analysis confirmed the availability of this feature 

on multiple clothes washer models from multiple manufacturers. However, DOE’s current test 

procedure at appendix J2 uses a fixed set Temperature Use Factors (TUFs), which represent the 

percentage of time an end-user would select each wash/rinse temperature selection available on 

the clothes washer. Because the TUFs in the test procedure are fixed, a clothes washer with 

temperature-differentiated pricing controls would be tested the same way as an identical clothes 

washer without temperature-differentiated pricing controls. Therefore, the energy savings of this 

technology cannot be measured according to the conditions and methods specified in the DOE 

clothes washer test procedure. Accordingly, DOE did not analyze this technology option in its

final rule analysis.

5.3 PRODUCT CLASSES ANALYZED

DOE separates commercial clothes washers into product classes and has formulated 

separate energy conservation standards for each class. The criteria for separation into different 

product classes are: (1) type of energy used; (2) capacity; or (3) 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)) 

As discussed in chapter 3 of this TSD, DOE has separated commercial clothes washers 

into two product classes for this rulemaking: top-loading and front-loading.
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5.4 EFFICIENCY LEVELS

5.4.1 Efficiency Metrics

The energy conservation standard levels for commercial clothes washers are currently 

defined by two factors—modified energy factor (MEF) and water factor (WF). MEF is 

calculated as the clothes container capacity in cubic feet divided by the sum, expressed in 

kilowatt-hours (kWh), of: (1) the total weighted per-cycle hot water energy consumption; (2) the 

total weighted per-cycle machine electrical energy consumption; and (3) the per-cycle energy 

consumption for removing moisture from a test load. WF is calculated as the weighted per-cycle 

water consumption of the cold wash/cold rinse cycle divided by the clothes container capacity in 

cubic feet.

The equations for calculating MEF and WF are as follows:

where:

C= Clothes container capacity (cubic feet)

HET = Total weighted per-cycle hot water energy consumption (kWh)

MET = Total weighted per-cycle machine electrical energy consumption (kWh)

DE= Per-cycle energy consumption for removal of moisture from test load (kWh)

where:

QT= Total weighted per-cycle water consumption of cold wash/cold rinse cycles (gallons)

C = Clothes container capacity (cu.ft.).

On March 7, 2012, DOE published a final rule amending its test procedures for 

residential clothes washers (“March 2012 final rule”). (77 FR 13888) The March 2012 final rule 

included minor amendments to the test procedure at 10 CFR 430, subpart B, appendix J1 and 

also established a new test procedure at appendix J2.Manufacturers of commercial clothes 

washers must use appendix J1 to demonstrate compliance with the current standards established 

by the January 2010 final rule. The use of appendix J2 will be required to demonstrate 

compliance with the amended energy conservation standards published in this final rule.

In the March 2012 final rule, DOE incorporated standby and off mode energy use with 

active mode energy use into an integrated metric, integrated modified energy factor (IMEF),

contained in the new appendix J2 test procedure. Appendix J2 also retains provisions for 

MEF =

C

HET + MET + DE

WF =

QT

C
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calculating modified energy factor, which DOE designates as MEFJ2. As described in greater 

detail in the final rule, the amended energy standards are based on MEFJ2 as measured using 

appendix J2.

Table 5.4.1 shows the major revisions included in the amended test procedure that affect 

the calculated efficiency metrics for commercial clothes washers.

Table 5.4.1 Revisions to the Clothes Washer Test Procedure that Significantly Affect 

Efficiency Metrics

Factors Affecting MEF Appendix J1 Appendix J2

Capacity measurement

For top-loading clothes 

washers: Innermost 

diameter of the tub cover. 

(Defined as “Fill Level 3” in 

DOE guidance document1)

For top-loading clothes 

washers: Uppermost edge of 

the rotating portion, including 

any balance ring. (Defined as 

“Fill Level 2” in DOE 

guidance document)

Dryer energy calculation

Based on Load Adjustment 

Factor (LAF) of 0.52 

multiplied by maximum test 

load weight

Based on weighted average 

load size according to existing 

Load Usage Factors (LUF).

Dryer Usage Factor (DUF) DUF = 0.84 DUF = 0.91

Factors Affecting WF / 

IWF Appendix J1 (WF) Appendix J2 (IWF)

Capacity measurement See above. See above.

Water Consumption

Based on water usage of 

Cold Wash / Cold Rinse 

cycles only.

Based on weighted average of 

water usage of all Wash / 

Rinse temperature 

combinations

The amended water efficiency standards in this final rule are based on the IWF metric, 

which incorporates water consumption from all the temperature cycles included as part of the 

energy test cycle in appendix J2. The IWF metric provides a more representative measure of 

water consumption than the WF metric, since it incorporates the water usage from all the 

wash/rinse temperature selections included for testing rather than just the cold/cold cycle, on 

which WF is based. The equation for IWF is as follows:

 

1 DOE issued guidance in May 2010 on what is considered the clothes container for purposes of measuring clothes 

container capacity. The guidance is available at the residential clothes washer rulemaking website, 

http://www1.eere.energy.gov/guidance/detail_search.aspx?IDQuestion=568&pid=2&spid=1

IWF =

QT

C
5-5

where:

QT= Total weighted per-cycle water consumption of all wash cycles (gallons)

C = Clothes container capacity (cu.ft.).

Current CCW product ratings are based on MEF and WF as measured using appendix J1. 

To define energy efficiency levels based on MEFJ2 and IWF as measured using appendix J2, 

DOE first conducted testing on a representative sample of CCWs, spanning the entire range of 

available efficiency levels, to determine each model’s corresponding appendix J2 rating. DOE 

then established baseline and higher efficiency levels based on the appendix J2 MEFJ2 and IWF 

ratings.

For convenience, throughout this TSD, DOE displays both the appendix J1 and appendix 

J2 ratings corresponding to each efficiency level.

5.4.2 Appendix J1/Appendix J2 Efficiency Metric Translations

Based on the test results described in section 5.6.2 of this TSD chapter, DOE translated 

the appendix J1 MEF/WF efficiency levels into appendix J2 MEFJ2/IWF efficiency levels for 

consideration in the final rule analysis. Table 5.4.2 shows the resulting efficiency level 

translations for top-loading CCWs. Table 5.4.3 shows the resulting efficiency level translations 

for front-loading CCWs.

Table 5.4.2 Appendix J1 and Appendix J2 Efficiency Level Translations for Top-Loading 

CCWs

Efficiency Level Efficiency Level 

Source

Appendix J1 Metrics Appendix J2 Metrics

MEF WF MEFJ2 IWF

Baseline DOE Standard 1.60 8.5 1.15 8.9

Level 1 Gap Fill 1.70 8.4 1.35 8.8

Level 2 Maximum Available 1.85 6.9 1.55 6.9
5-6

Table 5.4.3 Appendix J1 and Appendix J2 Efficiency Level Translations for Front-Loading 

CCWs

Efficiency Level Efficiency Level 

Source

Appendix J1 Metrics Appendix J2 Metrics

MEF WF MEFJ2 IWF

Baseline DOE Standard 2.00 5.5 1.65 5.2

Level 1 CEE Tier 2 2.20 4.5 1.80 4.5

Level 2 CEE Tier 3 2.40 4.0 2.00 4.1

Level 3 Maximum Available 2.60 3.7 2.20 3.9

The following sections describe the baseline and higher efficiency levels in greater detail.

5.4.3 Baseline Units

DOE selects baseline units as reference points for each product class. The baseline unit in 

each product class represents the basic characteristics of equipment in that class. Typically, a 

baseline unit is a unit that just meets current energy conservation standards and provides basic 

consumer utility. DOE uses the baseline units in the engineering analysis and the LCC and PBP

analysis. To determine energy savings and changes in price, DOE compares each higher energy

efficiency design option with the baseline unit. 

DOE established the baseline level for the top-loading product class based on the 1.60 

MEF and the 8.5 WF requirements specified by current Federal energy conservation standards, 

which became effective for commercial clothes washers manufactured on or after January 8, 

2013. For the front-loading product class, DOE established the baseline level based on the 2.00 

MEF and 5.5 WF requirements specified by current Federal energy conservation standards.

5.4.4 Higher Efficiency Levels

For the top-loading and front-loading product classes, DOE considered efficiency levels 

higher than baseline levels based on the Consortium for Energy Efficiency (CEE) former Tier 

levels for commercial clothes washers.2 The highest efficiency levels were defined by the 

maximum available technology that DOE could identify on the market. For the top-loading 

product class, DOE added an intermediate “gap fill” levels between the baseline and maximum 

available efficiency levels.

 

2 CEE has historically maintained a Commercial Clothes Washer Initiative that encourages the purchase and use of 

energy and water efficient commercial clothes washers. Given recent changes to federal minimum efficiency 

standards and ENERGY STAR criteria for commercial clothes washers, the CEE Commercial Clothes Washer 

Specification is not currently active. As a result, publication of the associated qualifying product list is also 

temporarily suspended.
5-7

5.4.5 Maximum Technologically Feasible Efficiency Levels

Under EPCA, DOE is required to consider the maximum technologically feasible level

(“max-tech”). DOE determines max-tech levels based on technologies that are either 

commercially available or have been demonstrated as working prototypes. If the max-tech design 

meets DOE’s screening criteria, DOE considers the design in further analysis. DOE also 

considers consumer utility and availability of features, which may be met by a niche product, as 

required by EPCA.

DOE identified the max-tech levels for top-loading and front-loading commercial clothes 

washers based on the maximum performance of products currently on the market in the United 

States. DOE has observed that the max-tech units on the market use a combination of reduced 

water volumes, reduced water temperatures, extended cycle times, higher spin speeds. DOE is 

not aware of any additional design options that could be used to increase the efficiency beyond 

the max-tech levels without causing potential negative effects on consumer utility. Nor is DOE 

aware of any working prototype clothes washers that exceed the efficiency levels of the max-tech 

units on the market in the United States. Therefore, DOE has determined that with the current 

state of technology for CCWs, the “max available” efficiency levels identified for top-loading 

and front-loading CCWs correspond to the maximum technologically feasible efficiency levels.

DOE notes, however, that further technological development in top-loading and front-loading 

clothes washer technologies could lead to higher max-tech levels in the future.

5.5 METHODOLOGY OVERVIEW

DOE conducted energy and water testing, cleaning and rinsing performance testing, and 

standby power testing on a representative sample of top-loading and front-loading CCWs 

spanning a range of efficiencies and manufacturers. The objective of this testing was to gain 

insights into the relative performance differences among the CCW models available on the 

market. DOE conducted its testing at an independent laboratory with significant experience 

performing clothes washer testing. Following testing, DOE performed detailed product 

teardowns and cost modeling to generate cost-efficiency curves for each product class. Finally, 

DOE conducted interviews with commercial clothes washer manufacturers to better understand 

and explain the differences among manufacturers in baseline unit construction, design strategies 

for achieving higher efficiency levels, and overall cost structures.

5.5.1 AHAM Data Request 

In support of this rulemaking effort, DOE requested incremental cost data from AHAM 

for commercial clothes washers. The AHAM data request is presented in Appendix 5-A to this 

TSD. The data represent the average incremental production cost to improve a baseline unit to a 

specified efficiency level. In addition, DOE requested shipments, shipment-weighted average 

efficiency, and market share efficiency data. AHAM’s data submissions are available in the 

docket for this rulemaking at regulations.gov.
5-8

5.5.2 Product Testing Methodology

DOE conducted performance testing on a range of CCW models for the following 

purposes:

 Determine equivalent MEFJ2 and IWF ratings using the new appendix J2 test procedure; 

 Verify performance trends that are apparent in the publicly available data;

 Develop a better understanding of the operational characteristics of CCWs; and

 Evaluate potential impacts on cleaning and rinsing performance as a result of higher 

efficiency levels.

DOE conducted testing on a representative sample of top-loading and front-loading 

CCWs spanning a range of efficiencies and manufacturers. DOE conducted its testing at an 

independent laboratory with significant experience performing clothes washer testing. DOE used 

the following test procedures for its testing:

 10 CFR 430, subpart B, Appendix J1, 

 10 CFR 430, subpart B, Appendix J2

 AHAM HLW-1-2010, Performance Evaluation Procedures for Household Clothes 

Washers3

Within AHAM HLW-1-2010, DOE performed the following tests:

 Soil/Stain Removal (Section 6)

 Sand Removal (Section 8)

 Rinsing Effectiveness Test (Annex E)

Section 5.6.2 provides detailed results of this testing.

5.5.3 Product Teardown Methodology

Other than obtaining detailed manufacturing costs directly from a manufacturer, the most 

accurate method for determining the production cost of a product is to disassemble representative 

units piece-by-piece and estimate the material, labor, and overhead costs associated with each 

component using a process commonly called a physical teardown. A supplementary method, 

called a catalog teardown, uses published manufacturer catalogs and supplementary component 

data to estimate the major physical differences between a product that has been physically 

disassembled and another similar product. DOE performed physical teardown analysis on both 

top-loading and front-loading commercial clothes washers. The teardown methodology is 

explained in the following sections.

 

3 Available from AHAM at http://www.aham.org/ht/d/ProductDetails/sku/4045-110-140/from/714/pid/ AHAM has 

since issued a revised version of this test method, HLW-1-2013. 
5-9

5.5.3.1 Selection of Units

DOE generally adopts the following criteria for selecting units for teardown analysis:

 The selected products should span the full range of efficiency levels for each product class 

under consideration;

 Within each product class, the selected products should, if possible, come from the same 

manufacturer and belong to the same product platform;

 The selected products should, if possible, come from manufacturers with large market shares 

in that product class, although the highest efficiency products are chosen irrespective of 

manufacturer; and

 The selected products should have non-efficiency-related features that are the same as, or 

similar to, features of other products in the same class and at the same efficiency level.

5.5.3.2 Generation of Bill of Materials

The end result of each teardown is a structured bill of materials (BOM), which describes 

each product part and its relationship to the other parts, in the estimated order of assembly. The 

BOMs describe each fabrication and assembly operation in detail, including the type of value—

added equipment needed (e.g., stamping presses, injection molding machines, spot-welders, etc.) 

and the estimated cycle times associated with each conversion step. The result is a thorough and 

explicit model of the production process. 

Materials in the BOM are divided between raw materials that require conversion steps to 

be made ready for assembly, while purchased parts are typically delivered ready for installation. 

The classification into raw materials or purchased parts is based on DOE’s previous industry 

experience, recent information in trade publications, and discussions with original equipment 

manufacturers (OEMs). For purchased parts, the purchase price is based on volume-variable 

price quotations and detailed discussions with suppliers. 

For parts fabricated in-house, the prices of the underlying “raw” metals (e.g., tube, sheet 

metal) are estimated on the basis of 5-year averages to smooth out spikes in demand. Other 

“raw” materials such as plastic resins, insulation materials, etc. are estimated on a current-market 

basis. The costs of raw materials are based on manufacturer interviews, quotes from suppliers, 

secondary research, and by subscriptions to publications including the American Metals Market 

(AMM).4 Past price quotes are indexed using applicable Bureau of Labor Statistics producer 

price index tables as well as AMM monthly data. 

5.5.3.3 Cost Structure of the Spreadsheet Models

The manufacturing cost assessment methodology uses a detailed, component-focused 

technique for rigorously calculating the manufacturing cost of a product (direct materials, direct 

 

4 For information on American Metals Market, please visit: www.amm.com.
5-10

labor and some overhead costs). Figure 5.5.1 shows the three major steps in generating the 

manufacturing cost.

Figure 5.5.1 Manufacturing Cost Assessment Stages

The first step in the manufacturing cost assessment is the creation of a complete and 

structured BOM from the disassembly of the units selected for teardown. The units are

dismantled, and each part is characterized according to weight, manufacturing processes used, 

dimensions, material, and quantity. The BOM incorporates all materials, components, and 

fasteners with estimates of raw material costs and purchased part costs. Assumptions on the 

sourcing of parts and in-house fabrication are based on industry experience, information in trade 

publications, and discussions with manufacturers. Interviews and plant visits are conducted with 

manufacturers to ensure accuracy on methodology and pricing.

Following the development of a detailed BOM, the major manufacturing processes are

identified and developed for the spreadsheet model. Some typical processes are listed in Table 

5.5.1.

Table 5.5.1 Major Manufacturing Processes

Fabrication Finishing Assembly/Joining Quality 

Control

Fixturing

Stamping/Pressing

Brake Forming

Cutting and 

Shearing

Insulating

Turret Punch

Tube Forming

Enameling

Washing

Powder 

Coating

De-burring

Polishing

Refrigerant 

Charging

Adhesive Bonding

Spot Welding

Seam Welding

Packaging

Inspecting & 

Testing

Fabrication process cycle times for each part made in-house are estimated and entered 

into the BOM. Based on estimated assembly and fabrication time requirements, the labor content 

of each appliance can be estimated.

Cycle requirements for fabrication steps are similarly aggregated by fabrication machine 

type while accounting for dedicated vs. non-dedicated machinery and/or change-over times (die 

swaps in a press, for example). Once the cost estimate for each teardown unit are finalized, a 

detailed summary is prepared for relevant components, subassemblies and processes. The BOM 

thus details all aspects of unit costs: material, labor, and overhead. 
5-11

Design options used in units subject to teardown are noted in the summary sheet of each 

cost model and are cost-estimated individually. Thus, various implementations of design options 

can be accommodated, ranging from assemblies that are entirely purchased to units that are made 

entirely from raw materials. Hybrid assemblies, consisting of purchased parts and parts made on 

site are thus also accommodated.

5.5.3.4 Cost Model and Definitions

The cost model is based on production activities and divides factory costs into the 

following categories:

 Materials: Purchased parts (i.e., motors, valves, etc.), raw materials, (i.e., cold rolled 

steel, copper tube, etc.), and indirect materials that are used for processing and 

fabrication.

 Labor: Fabrication, assembly, indirect, and supervisor labor. Fabrication and assembly 

labor cost are burdened with benefits and supervisory costs.

 Overhead: Equipment, tooling, and building depreciation, as well as utilities, equipment 

and tooling maintenance, insurance, and property taxes.

Cost Definitions

Because there are many different accounting systems and methods to monitor costs, DOE 

defined the above terms as follows:

 Direct material: Purchased parts (out-sourced) plus manufactured parts (made in-house 

from raw materials).

 Indirect material: Material used during manufacturing (e.g., welding rods, adhesives).

 Fabrication labor: Labor associated with in-house piece manufacturing.

 Assembly labor: Labor associated with final assembly.

 Supervisory labor: Labor associated with fabrication and assembly basis. Assigned on a 

span basis (x number of employees per supervisor) that depends on the industry.

 Indirect labor: Labor costs that scale with fabrication and assembly labor. These included 

the cost of technicians, manufacturing engineering support, stocking, etc. that are 

proportional to all other labor. 

 Equipment depreciation: Money allocated to pay for initial equipment installation and 

replacement as the production equipment is amortized. All depreciation is assigned in a 

linear fashion and affected equipment life depends on the type of equipment.

 Tooling depreciation: Cost for initial tooling (including non-recurring engineering and 

debugging of the tools) and tooling replacement as it wears out or is rendered obsolete.

 Building depreciation: Money allocated to pay for the building space and the conveyors 

that feed and/or make up the assembly line.

 Utilities: Electricity, gas, telephones, etc.

 Maintenance: Annual money spent on maintaining tooling and equipment.

 Insurance: Appropriated as a function of unit cost.

 Property Tax: Appropriated as a function of unit cost.
5-12

5.5.3.5 Cost Model Assumptions

As discussed in the previous section, assumptions about manufacturer practices and cost 

structure played an important role in estimating the final product cost. In converting physical 

information about the product into cost information, DOE reconstructed manufacturing processes 

for each component using internal expertise and knowledge of the methods used by the industry. 

Site visits allowed DOE to confirm its cost model assumptions through direct observation of the 

manufacturing plant, as well as through manufacturer interviews, reviews of current Bureau of 

Labor Statistics data, etc.

5.5.4 Manufacturer Interviews

DOE understands that there is variability among manufacturers in baseline units, design 

strategies, and cost structures. To better understand and explain these variances, DOE conducted

manufacturer interviews. These confidential interviews provided a deeper understanding of the 

various combinations of technologies used to increase residential clothes washer efficiency, and 

their associated manufacturing costs. Sample questions asked during the interviews are contained 

in appendix 12A.

During the interviews, DOE also gathered information about the capital expenditures 

required to increase the efficiency of the baseline units to various efficiency levels (i.e., 

conversion capital expenditures by efficiency or energy-use level). The interviews provided 

information about the size and the nature of the capital investments. DOE also requested 

information about the depreciation method used to expense the conversion capital. The 

manufacturer impact analysis in chapter 12 includes a discussion of this information obtained 

during manufacturer interviews.

5.6 ANALYSIS AND RESULTS

5.6.1 AHAM Data

In its data submittal to DOE, AHAM stated that it has not collected incremental cost data 

from CCW manufacturers and therefore cannot provide that data to DOE.

5.6.2 Product Testing Results

DOE tested a total of 10 commercial clothes washer models in support of this 

rulemaking: five top-loading and five front-loading units. DOE also conducted teardowns on 

these 10 clothes washer models. DOE selected clothes washer models for testing and teardowns 

that spanned the range of product efficiencies available on the market. Table 5.6.1 lists the major 

features of the top-loading CCWs observed at each efficiency level. Table 5.6.2 lists the major 

features of front-loading CCWs observed at each efficiency level. The efficiency levels listed in 

these tables correspond to the levels shown above in Table 5.4.2 and Table 5.4.3. Note that for 
5-13

top-loading Units #2 and #3, the Efficiency Level changes depending on whether Appendix J1 or 

Appendix J2 is used. The next section below provides further details regarding the test result 

differences between Appendix J1 and Appendix J2.

Table 5.6.1 Top-Loading Commercial Clothes Washer Test Unit Features

Feature Unit #1 Unit #2 Unit #3 Unit #4 Unit #5

Appendix J2 Efficiency 

Level (MEFJ2/IWF)

Baseline

(1.15/8.9)

Baseline

(1.15/8.9)

Level 1

(1.35/8.8)

Level 1

(1.35/8.8)

Level 2

(1.55/6.9)

Appendix J1Efficiency 

Level (MEF/WF)

Baseline

(1.60/8.5)

Level 1

(1.70/8.4)

Baseline

(1.15/8.9)

Level 1

(1.70/8.4)

Level 2

(1.85/6.9)

Efficiency Level WF 

(Appendix J2 IWF) [gal/ 

ft3]

8.5 (8.9) 8.4 (8.8) 8.5 (8.9) 8.4 (8.8) 6.9 (6.9)

Rated Drum Capacity (ft3) 3.5 3.3 3.3 3.3 2.9

Remaining Moisture 

Content (%) 50.8% 48.1% 49.5% 48.0% 47.2%

Control Panel Type No vend 

display

Vend 

price 

display + 

advanced 

features1

No vend 

display

Vend 

price 

display

No vend 

display

Payment System Type

None 

(“push to 

start”)

Coin box Coin box Coin box Coin slide

Advanced Auditing or 

Remote

Communication Features

No Yes No No No

Water Fill Control Manual Manual Automatic 

Fixed 

Automatic 

Fixed 

Automatic 

Adaptive

Agitator Type Standard Standard Standard Standard LowProfile

Internal Heater No No No No No

1. Advanced features may include dynamic or cycle-based pricing controls, built-in logging capabilities, and 

remote auditing features.
5-14

Table 5.6.2 Front-Loading Commercial Clothes Washer Test Unit Features

Feature Unit #1 Unit #2 Unit #3 Unit #4 Unit #5

Appendix J2 Efficiency 

Level (MEFJ2/IWF)

Level 1

(1.80/4.5)

Level 1

(1.80/4.5)

Level 2

(2.00/4.1)

Level 2

(2.00/4.1)

Level 3

(2.20/3.9)

Appendix J1 Efficiency 

Level (MEF/WF)

Level 1

(2.20/4.5)

Level 1

(2.20/4.5)

Level 2

(2.40/4.0)

Level 2

(2.40/4.0)

Level 3

(2.60/3.7)

Rated Drum Capacity (ft3) 2.8 3.1 2.8 3.1 3.6

Remaining Moisture 

Content (%) 39.6% 37.9% 39.6% 35.5% 33.4%

Control Panel Type

Vend 

price 

display + 

advanced 

features1

Vend 

price 

display

Vend 

price 

display + 

advanced 

features1

Vend 

price 

display

No vend 

display

Payment System Type Coin box Coin box Coin box Coin box

None 

(“push to 

start”)

Advanced Auditing or 

Remote

Communication Features

Yes No Yes No No

Water Fill Control Automatic 

Adaptive

Automatic 

Adaptive

Automatic 

Adaptive

Automatic 

Adaptive

Automatic 

Adaptive

Internal Heater No No No No No

1. Advanced features may include dynamic or cycle-based pricing controls, built-in logging capabilities, and 

remote auditing features.

5.6.2.1 Active Mode Testing

DOE conducted testing on a representative sample of five top-loading and five frontloading CCWs using both appendix J1 and appendix J2. DOE used the results from these tests to 

determine each model’s appendix J2 MEFJ2/IWF ratings in relation to its appendix J1 MEF/WF 

ratings. These relationships were then used to develop the equivalent Appendix J2 values for 

each Appendix J1 efficiency level shown in Table 5.4.2 and Table 5.4.3.

The DOE test procedure consists of running different load sizes of preconditioned test 

cloth in the clothes washer at various temperature settings. For all clothes washers, the minimum 

test load is 3 pounds of test cloth. Average and maximum load sizes are specified based on the 

clothes washer capacity. During the energy test cycles, the total kWh of electric energy 

consumed by the clothes washer is measured, in addition to the cold and hot water consumption. 
5-15

The measurements also include the “bone dry”5 weight of the test load and the weight 

immediately after the completion of certain energy test cycles for the Remaining Moisture 

Content (RMC) calculation.

Figure 5.6.1 shows a plot of the equivalent MEFJ2 values (using appendix J2) associated 

with the rated MEF values (using appendix J1) for each of the top-loading CCWs in the test 

sample. For reference, the plot also indicates the associated efficiency levels used for the 

rulemaking analysis, based on appendix J2 MEFJ2 ratings. 

Figure 5.6.1 Relationship Between Equivalent MEFJ2 (Appendix J2) and Rated MEF 

(Appendix J1) for Top-Loading CCWs 

Figure 5.6.1 shows that top-loading clothes washers with manual water fill controls have 

lower relative appendix J2 MEFJ2 ratings compared to similarly-rated units (based on appendix 

J1) with automatic water fill controls.6 As a result, some manual water fill units that would have 

been considered higher-efficiency models under appendix J1 ratings are considered baseline 

models under appendix J2 ratings.

The primary driver of the lower relative efficiency ratings under appendix J2 for units 

with manual water fill controls is the amended calculation of drying energy in section 4.3 of 

 

5

“Bone dry” means a condition of a load of test clothes which has been dried in a dryer at maximum temperature for 

a minimum of 10 minutes, removed and weighed before cool down, and then dried again for 10-minute periods until 

the final weight change of the load is 1 percent or less.

6 The term “automatic” water fill used here refers to water fill control systems that determine the water fill level 

without requiring user intervention or actions. This includes “adaptive” water fill control systems and “fixed” water 

fill control systems, available on some commercial clothes washers, that provide a fixed water level for all load sizes 

and no water fill selector or water fill control settings available to the user.
5-16

appendix J2. In appendix J2, the drying energy is calculated using the weighted average load 

size, with the weightings corresponding to the Load Usage Factors (LUF) for manual water fill 

machines. Whereas, in section 4.3 of appendix J1, the drying energy is calculated using an 

adjusted load size equal to 0.52 x Maximum Load Size. The calculated drying energy using 

appendix J2 is a greater quantity than under appendix J1; thus resulting in a lower MEFJ2 value. 

For units with adaptive fill controls, the difference between the weighted average load size in 

appendix J2 and the adjusted load size in appendix J1 is much less; therefore, the difference in 

drying energy is not as pronounced as with manual water fill units.

Figure 5.6.2 shows a plot of the equivalent IWF values (using appendix J2) associated 

with the rated WF values (using appendix J1) for each of the top-loading CCWs in the test 

sample. For reference, the plot also indicates the associated efficiency levels used for the 

rulemaking analysis, based on appendix J2 IWF ratings. 

Figure 5.6.2 Relationship Between Equivalent IWF (Appendix J2) and Rated WF 

(Appendix J1) for Top-Loading CCWs

Figure 5.6.3 shows a plot of the equivalent MEFJ2 values (using appendix J2) associated 

with the rated MEF values (using appendix J1) for each of the front-loading CCWs in the test 

sample. For reference, the plot also indicates the associated efficiency levels used for the 

rulemaking analysis, based on appendix J2 MEFJ2 ratings. 
5-17

Figure 5.6.3 Relationship Between Equivalent MEFJ2 (Appendix J2) and Rated MEF 

(Appendix J1) for Front-Loading CCWs

DOE is not aware of any front-loading CCWs on the market with a rating of 2.00 MEF, 

which corresponds to the current minimum standard level. As a result, DOE used data from the 

prior CCW rulemaking to represent the 2.00 MEF level, indicated in Figure 5.6.3 as a “virtual 

model.” To calculate the equivalent appendix J2 MEFJ2 for the virtual model, DOE assumed that 

a model with a 2.00 MEF rating under appendix J1 would have the same measured capacity, 

machine electrical, and hot water heating energy under appendix J2. The only change would be 

the drying energy calculation, as described above.

Figure 5.6.4 shows a plot of the equivalent IWF values (using appendix J2) associated 

with the rated WF values (using appendix J1) for each of the front-loading CCWs in the test 

sample. For reference, the plot also indicates the associated efficiency levels used for the 

rulemaking analysis, based on appendix J2 IWF ratings.
5-18

Figure 5.6.4 Relationship Between Equivalent IWF (Appendix J2) and Rated WF 

(Appendix J1) for Front-Loading CCWs

5.6.2.2 Standby Mode and Off Mode Power

The amended energy standards established by this final rule are based on MEFJ2, which 

does not incorporate standby and off mode power. As part of its investigational testing, however, 

DOE measured standby and off mode power for all 10 clothes washers selected in the test 

sample, using the methodology provided in Appendix J2, which references International 

Electrotechnical Commission (IEC) Standard 62301 Second Edition.

CCW manufacturers offer a variety of display and payment functionalities that can be 

selected independent of the basic model selected. The standby power associated with these 

different display and payment functionalities varies widely. The lowest standby power levels are 

associated with models having no vend price display and no coin or card payment options (often 

referred to as “push-to-start” models). These models are typically used in multi-family housing 

facilities offering free laundry, or in other commercial applications not requiring fare payment. 

Such models are not suitable for coin-operated laundry or most multi-family housing facilities. 

The highest standby power levels are associated with models having a digital vend price display, 

coin or debit card payment system, and advanced features such as dynamic or cycle-based 

pricing controls, built-in logging capabilities, and remote auditing features. These models are 

typically used in coin-operated laundries located in competitive markets.

The results of the standby and off mode measurements are shown in Table 5.6.3 below.
5-19

Table 5.6.3 Commercial Clothes Washer Standby Power Measurements

Product 

Class

Rated 

MEF 

(ft3/kWh) Control Panel Type

Payment 

System 

Type

Power 

Consumpti

on (W)

TopLoading

1.60 No vend display Push-to-start 2.84

1.65 No vend display Coin slot 5.44

1.70 Vend price only Coin slot 10.21

1.75 Vend price display + advanced 

features1 Coin slot 11.77

1.85 No vend display Coin slide 0.88

FrontLoading

2.24 Vend price display + advanced 

features1 Coin slot 11.60

2.24 Vend price only Coin slot 7.10

2.46 Vend price display + advanced 

features1 Coin slot 11.30

2.49 Vend price only Coin slot 7.70

2.60 Vend price only Push-to-start 5.80

1. Advanced features may include dynamic or cycle-based pricing controls, built-in logging capabilities, and 

remote auditing features.

5.6.2.3 Cleaning Performance Testing

To investigate potential impacts on cleaning performance, rinsing performance, and solid 

particle removal, DOE performed additional testing on each model using AHAM’s HLW-1-2010 

test method: Performance Evaluation Procedures for Household Clothes Washers (hereafter, 

“AHAM HLW-1-2010”). Specifically, DOE performed the soil/stain removal, rinsing 

effectiveness, and sand removal tests provided in HLW-1-2010. For each clothes washer, DOE 

tested the maximum load size specified in appendix J2, rounded to the nearest pound, using the 

warm wash/cold rinse cycle. DOE believes that the maximum load size is particularly relevant to 

commercial clothes washer owners and operators because end-users often overload the machines 

in order to limit their total laundry cost.

DOE consulted with a number of manufacturers who indicated that AHAM HLW-1-2010 

would be the most appropriate test method to determine relative cleaning performance across 

different commercial clothes washer models. DOE recognizes that AHAM HLW-1-2010 is 

typically used to measure the performance of residential clothes washers, but given the 

similarities in physical construction, DOE believes the test procedure is also appropriate for 

commercial clothes washers covered by DOE standards. DOE also acknowledges that the 

commercial clothes washer industry has not agreed upon acceptable ranges of performance 

characteristics. DOE also recognizes that the tests described below were conducted using a single 
5-20

load size and wash/rinse temperature, and that such results may not provide a complete 

characterization of each model’s performance. Therefore, for these reasons, the test results 

provided below should be considered informative in nature and used for relative comparison 

purposes only.

Cleaning Performance

DOE performed the Soil/Stain Removal test within section 6 of AHAM HLW-1-2010 to 

measure relative cleaning performance among the CCW test sample units. AHAM HLW-1-2010 

states that the purpose of the Soil/Stain Removal test is to evaluate the performance of household 

clothes washers in removing representative soils and stains from fabric. For each clothes washer, 

DOE tested the maximum load size specified in appendix J2, rounded to the nearest pound, and 

used the warm wash/cold rinse cycle.

The AHAM HLW-1-2010 Soil/Stain Removal test consists of running a wash cycle with 

user-defined test load size and machine settings, using AHAM base load materials, a defined 

number of soil/stain strips, and a defined quantity of powdered AHAM detergent. The AHAM 

base load materials consist of 100% cotton sheets, towels, and pillowcases. The soil/stain strips

consist of square test fabric swatches measuring 4.7 in. x 4.7 in., carrying five different types of 

standard stains in addition to a sixth unstained swatch. The swatches are attached to each other, 

forming a test strip with the different stains in the following order:

1. Unsoiled

2. Pigment/sebum

3. Carbon black/mineral oil.

4. Blood.

5. Chocolate and milk.

6. Red wine

Figure 5.6.5 shows the soil/stain strips, including typical packaging material. The photo includes 

a printed copy of the AHAM HLW-1-2010 test procedure for scale.
5-21

Figure 5.6.5 AHAM Soil/Stain Test Strip

Multiple stain strips are attached to individual towels comprising the test load. AHAM 

HLW-1-2010 defines the number of test strips based on the total load size. Three replications of 

the Soil/Stain Removal test are performed on each clothes washer, using fresh soil/stain strips for 

each replication.

After a single wash cycle replication is performed, the soil/stain test strips are removed 

from the base load and measured using a tristimulus colorimeter. The unsoiled swatches are 

removed and used for the Rinsing Effectiveness test, as described in the next section of this 

chapter. The reflectance values of each stain swatch are measured; higher reflectance represents 

better stain removal. For each stain type, the reflectance values measured from all soil/stain test 

strips are averaged to produce an average reflectance score, yw lab for each stain. For each stain 

type, an Individual Cleaning Score, CSi, is obtained, expressed as:

where for each soil/stain:

ymax lot = post-wash reflectance as determined by the strip manufacturer using the 

calibration wash treatment defined in Annex A.A.7.1 of HLW-1-2010;

yw lab = post-wash reflectance as measured by laboratory.

CSi is determined for each stain type after each wash cycle replication. After the three 

replications have been performed, the three CSi scores for each stain type are averaged, to 

produce a mean CSi score for each stain type. A Total Cleaning Score, CSt, is then determined by 

averaging the mean CSi scores for all five stain types and multiplying by 100:

CSi =

yw lab

ymax lot

CSt =

 CSi × 100 5

i=1

5
5-22

The Total Cleaning Score represents cleaning performance as a percentage of that 

achieved by a reference “maximum” wash cycle determined by the calibration wash treatment 

performed by the stain strip manufacturer. The Total Cleaning Score may be less than or greater 

than 100%. A higher Total Cleaning Score represents better cleaning performance.

Top-Loading Results

Figure 5.6.6 shows the Total Cleaning Score for each top-loading CCW included in the 

test sample as a function of each washer’s appendix J2 MEFJ2 efficiency level. Figure 5.6.7

shows the Total Cleaning Score for each top-loading CCW as a function of each washer’s 

appendix J2 IWF efficiency level. As shown in both figures, some of the higher-efficiency 

clothes washers in the test sample actually achieve better Total Cleaning Scores than the baseline 

models. The amended standard in this final rule corresponds to Efficiency Level 1 (1.35 MEFJ2 / 

8.8 IWF).

Figure 5.6.6 Total Cleaning Score vs. Appendix J2 MEFJ2 Efficiency Level for TopLoading CCWs
5-23

Figure 5.6.7 Total Cleaning Score vs. Appendix J2 IWF Efficiency Level for Top-Loading 

CCWs

Figure 5.6.8 shows the Total Cleaning Score for each top-loading CCW as a function of 

each washer’s cycle time, as measured during the AHAM HLW-1-2010 test. DOE notes that 

these cycle times may not correspond to the same cycle times when conducting the DOE 

appendix J2 test procedure, due to differences in the base load material that may affect any 

adaptive control strategies used throughout the wash cycle. However, DOE believes that the 

cycle times shown in the figure are likely to be representative of consumer usage in a coinoperated laundry or multi-family housing laundry setting. As shown in the figure, one of the 

CCW models at Efficiency Level 1 achieves a better cleaning performance score than baseline 

models, at a cycle time of just under 30 minutes.

Figure 5.6.8 Total Cleaning Score vs. Cycle Time for Top-Loading CCWs
5-24

Front-Loading Results

Figure 5.6.9 shows the Total Cleaning Score for each front-loading CCW included in the 

test sample as a function of each washer’s appendix J2 MEFJ2 efficiency level. Figure 5.6.10

shows the Total Cleaning Score for each front-loading CCW as a function of each washer’s 

appendix J2 IWF efficiency level. DOE notes that one Level 2 clothes washer achieves 

equivalent or better performance than both Level 1 clothes washers. The amended standard in 

this final rule corresponds to Efficiency Level 2 (2.00 MEFJ2 / 4.1 IWF).

Figure 5.6.9 Total Cleaning Score vs. Appendix J2 MEFJ2 Efficiency Level for FrontLoading CCWs

Figure 5.6.10 Total Cleaning Score vs. Appendix J2 IWF Efficiency Level for FrontLoading CCWs
5-25

Figure 5.6.11 shows the Total Cleaning Score for each front-loading CCW as a function 

of each washer’s cycle time, as measured during the AHAM HLW-1-2010 test. As shown in the 

figure, cycle times for Efficiency Level 2 clothes washers range from around 31 minutes to just 

over 36 minutes. The range of cycle times for the Level 1 models is approximately 31 to 34 

minutes.

Figure 5.6.11 Total Cleaning Score vs. Cycle Time for Front-Loading CCWs

Rinsing Performance

The AHAM Rinsing Effectiveness test consists of measuring the concentration of 

detergent remaining in the unstained swatches after performing the Soil/Stain Removal tests 

described in the previous section. This is accomplished by measuring the UV absorbance at the 

wavelength particular to LAS (surfactant), a key ingredient of the detergent with a known linear 

relationship to the quantity of detergent mixture. Using a concentration vs. absorbance curve 

developed as part of this procedure, the absorbance values are then converted into detergent 

concentrations, which together with test solution weight data, yields detergent quantities.

After a single wash cycle replication is performed, the unsoiled test strips are removed 

and each strip is placed into an individual bottle with 100ml distilled water. After all the test 

strips have been bottled, they are placed on a laboratory shaker for 20 minutes. Following that, 

samples of the fluid from each bottle are then collected and measured in a UV 

spectrophotometer. The measured values are translated into detergent concentrations using the 

detergent concentration curves developed at the beginning of the procedure. The detergent 

concentration is then used to determine the amount of detergent recovered per gram of swatch 
5-26

material. The final Rinse Score is then calculated as the amount of detergent, in grams, 

remaining in a pound of test load. A lower Rinse Score represents better rinsing performance.

Top-Loading Results

Figure 5.6.12 shows the Rinse Score for each top-loading CCW included in the test 

sample as a function of each washer’s appendix J2 MEFJ2 efficiency level. Figure 5.6.13 shows 

the Rinse Score for each top-loading CCW as a function of each washer’s appendix J2 IWF 

efficiency level. DOE notes that the highest-efficiency washer at Efficiency Level 2 achieves a 

rinse score within the range of rinse scores achieved by the baseline models. The amended 

standard in this final rule corresponds to Efficiency Level 1 (1.35 MEFJ2 / 8.8 IWF).

Figure 5.6.12 Rinse Score vs. Appendix J2 MEFJ2 Efficiency Level for Top-Loading CCWs

Figure 5.6.13 Rinse Score vs. Appendix J2 IWF Efficiency Level for Top-Loading CCWs
5-27

Figure 5.6.14 shows the Rinse Score for each top-loading CCW as a function of each 

washer’s cycle time, as measured during the AHAM HLW-1-2010 test.

Figure 5.6.14 Rinse Score vs. Cycle Time for Top-Loading CCWs

Front-Loading Results

Figure 5.6.15 shows the Rinse Score for each front-loading CCW included in the test 

sample as a function of each washer’s appendix J2 MEFJ2 efficiency level. Figure 5.6.16 shows 

the Rinse Score for each front-loading CCW as a function of each washer’s appendix J2 IWF 

efficiency level. DOE notes that one of the Level 2 models achieves the lowest (best) Rinse 

Score of the entire test sample, at around 0.8. The amended standard level established by this 

final rule corresponds to Efficiency Level 2.
5-28

Figure 5.6.15 Rinse Score vs. Appendix J2 MEFJ2 Efficiency Level for Front-Loading 

CCWs

Figure 5.6.16 Rinse Score vs. Appendix J2 IWF Efficiency Level for Front-Loading CCWs

Figure 5.6.17 shows the Rinse Score for each front-loading CCW as a function of each 

washer’s cycle time, as measured during the AHAM HLW-1-2010 test. 
5-29

Figure 5.6.17 Rinse Score vs. Cycle Time for Front-Loading CCWs

Sand Removal Performance

DOE performed the Sand Removal test within section 8 of AHAM HLW-1-2010, the 

purpose of which is to evaluate the ability of a clothes washers to remove insoluble and heavierthan-water soils from clothes and the system. For each clothes washer, DOE tested the maximum 

load size specified in appendix J2, rounded to the nearest pound, and used the warm wash/cold 

rinse cycle. The Sand Removal test is performed separately from the Soil/Stain Removal and 

Rinsing Effectiveness tests. Three replications of the test are performed.

The AHAM HLW-1-2010 Sand Removal test consists of running a wash cycle with userdefined test load size and machine settings, using AHAM base load materials, a defined quantity 

of powdered AHAM detergent, and 50 grams of sand added to the load. During the wash cycle, 

sand is collected through a filter placed at the end of the clothes washer drain hose. Upon 

completion of the wash cycle, the test load is removed and any sand particles remaining in the 

clothing load are captured and measured. The Sand Remaining score, SR, is calculated as the 

quantity of sand remaining in the load (in grams) divided by the amount of sand added to the 

load (50 grams). A lower SR score represents better sand removal performance.

During testing, some sand may remain trapped in the clothes washer after each 

replication. Therefore, after each replication, “cleanup cycles” with no load are performed to 

flush out any sand remaining inside the washer. However, in some cases, despite running 

multiple cleanup cycles, not all the sand was accounted for after each replication of the test. 

Therefore, the second and third replications of each test may contain sand carried over from prior 
5-30

tests. DOE notes that because of these uncertainties, it is important to look at the SR scores from 

the three replications individually, rather than averaging them together.

Top-Loading Results

Figure 5.6.18 shows the Sand Removal Score for each top-loading CCW included in the 

test sample as a function of each washer’s appendix J2 MEF J2 efficiency level. Figure 5.6.19

shows the Sand Removal Score for each top-loading CCW as a function of each washer’s 

appendix J2 IWF efficiency level. As shown in both figures, current baseline clothes washers 

achieve a minimum sand removal score of 2%; Level 1 washers achieve a minimum score of 

around 4%, and Level 2 washers achieve a minimum score of 6%. The upper bound of the range 

is around 16% at all efficiency levels. The amended standard level established by this final rule 

corresponds to Efficiency Level 1.

Figure 5.6.18 Sand Removal Score vs. Appendix J2 MEFJ2 Efficiency Level for TopLoading CCWs
5-31

Figure 5.6.19 Sand Removal Score vs. Appendix J2 IWF Efficiency Level for Top-Loading 

CCWs

Figure 5.6.20 shows the Sand Removal Score for each front-loading CCW included in the 

test sample as a function of each washer’s appendix J2 MEF J2 efficiency level. Figure 5.6.21

shows the Sand Removal Score for each front-loading CCW as a function of each washer’s 

appendix J2 IWF efficiency level. As shown in both figures, current Level 1 clothes washers 

achieve sand removal scores ranging from 7-17%; Level 2 washers achieve scores ranging from 

5-10%; and Level 3 washers achieve scores ranging from 12-14%. The amended standard level 

established by this final rule corresponds to Efficiency Level 2.
5-32

Figure 5.6.20 Sand Removal Score vs. Appendix J2 MEFJ2 Efficiency Level for FrontLoading CCWs

Figure 5.6.21 Sand Removal Score vs. Appendix J2 IWF Efficiency Level for FrontLoading CCWs
5-33

5.6.3 Product Teardowns

As part of its reverse-engineering process, DOE conducted teardowns of commercial 

clothes washers to identify design features and corresponding manufacturing costs that are 

associated with successively higher efficiency levels. The clothes washer teardown analysis 

performed for this analysis included five top-loading and five front-loading models. Details of 

the teardown results are as follows.

5.6.3.1 Top-Loading Commercial Clothes Washers

Top-Loading Baseline Construction (1.15 MEFJ2 / 8.9 IWF)

The baseline top-loading CCW is equipped with electronic controls that allow the user to 

select specific cycle settings, including wash/rinse temperature and load size. Temperature is 

controlled using a thermal cutout on the water inlet assembly, which consists of two solenoid 

valves. The load size selector switch determines the fill level for a wash cycle, which is 

controlled by a pressure switch. Between 2-4 load size selections may be available on baseline 

units.

The motor is typically a 1⁄2-horsepower permanent split capacitor (PSC) motor which 

drives the drum and the agitator. On some baseline models, this motor also drives the drain pump 

by reversing direction, while other manufacturers opt to include a dedicated drain pump instead. 

The baseline wash basket consists of either an enameled steel or stainless steel cylinder with a

circular plate attached to the bottom to form a drum. From the center of the bottom plate a 

smaller cylinder rises to guide the drive shaft into the agitator and to center the wash basket 

inside the tub. Snapped onto the top rim of the drum is a plastic balance ring, which is partially 

filled with a saline solution. Covering the balance ring is a plastic cover, often referred to as the 

tub cover.

The outer wrapper of the baseline unit consists of stamped metal panels which may be 

made of pre-painted steel or coated post-fabrication with powder-coat paint. The top panel 

houses the lid, which is a smaller stamped piece of sheet metal on hinges. One of these hinges 

triggers a limit switch that cuts power to the motor when the lid is opened. The top panel and lid 

are typically enameled to provide greater scratch resistance.

Based upon product teardowns, DOE developed the following baseline production and 

materials cost distributions for a typical top-loading CCW. Table 5.6.4 and Figure 5.6.22 show 

the baseline production cost distributions; and Table 5.6.5 and Figure 5.6.23 show the baseline 

materials cost distribution. Depending on the manufacturer and the production volume, the 

depreciation costs may vary from those shown in the figures, which assume a “green-field” site.
5-34

Table 5.6.4 Production Cost Distribution for Baseline Top-Loading CCW 

Cost Category

Total 

Cost

($2013)

Figure 5.6.22 Production Cost Distribution for Baseline 

Top-Loading CCW

Raw Materials $75.39

Purchased Parts $164.29

Assy Labor Cost $18.49

Fab Labor Cost $28.16

Indirect Labor Cost $2.43

Supervision Cost $16.20

Tooling Dep. Cost $60.55

Indirect Process Costs $26.34

Equipment Dep. Cost $51.05

Building Dep. Cost $21.60

Maintenance $53.48

Utility Cost $5.49

Property Tax $4.71

Insurance $4.23

Total $532.40

Table 5.6.5 Materials Cost Distribution for Baseline Top-Loading CCW

Sub-Assembly

Total 

Materials 

Cost ($2013)

Figure 5.6.23 Baseline Top-Load Standard Clothes 

Washer Materials Cost Distribution

Motor/Pump/Capacitor $62.22 

Control Assy $38.65 

Gear Box/Transmission $30.54 

Tub/Drum $29.40 

Outer Wrapper $25.42 

Suspension $15.93 

Door Assy $10.65 

Main Wiring Harness $10.09 

Packaging $9.87 

Water Temp. Mgmt. $3.98 

Final Assy $2.93 

Total $239.68
5-35

Construction at Higher Efficiency Levels

Based on the design options retained from the screening analysis (see chapter 4 of this 

TSD), the reverse-engineering analyses, and discussions with manufacturers, DOE developed 

manufacturing costs associated with various design features necessary to achieve higher 

efficiencies. The following are the design changes DOE believes would be necessary to meet 

each higher efficiency level, which were subsequently modeled to obtain incremental 

manufacturing cost estimates.

Top-Loading Efficiency Level 1 (1.35 MEFJ2 / 3.8 IWF)

Based on characteristics of units selected for teardown and based on discussions with 

manufacturers, DOE research suggests that Efficiency Level (EL) 1 is typically achieved in toploading commercial clothes washers through the following changes:

1. Automatic Water Fill Control

Through its observations and discussions with manufacturers, DOE believes that in 

moving from the baseline level to EL 1, manufacturers would likely replace manual water fill 

controls, in which the end-user selects the fill level, with automatic water fill controls, in which 

the machine automatically selects the water fill level. The test procedure assumes a different set 

of Load Usage Factors (LUF) for manual and automatic water fill machines. For manual water 

fill machines, the LUF for the maximum load size is 72% (with the minimum load size TUF as 

28%), whereas for automatic water fill machines, the maximum load size LUF is 12% (with the 

average load size TUF as 74%, and minimum load size TUF as 14%).

2. Reduced Hot Water Temperatures

DOE believes that in addition to using automatic water fill controls, manufacturers may 

slightly reduce the temperature of the hot and warm water settings compared to the baseline unit. 

Top-Loading Efficiency Level 2 (1.55 MEFJ2 / 6.9 IWF)

DOE research suggests that manufacturers would likely significantly change the design 

platform of a top-loading commercial clothes washer to reach EL 2. A CCW at EL 2 is likely to 

employ the same features as one at EL 1, and would incorporate the following additional 

features:

1. Improved Fill Level Control

Manufacturers would likely improve the automatic fill control at EL2, which would 

include more accurate water level sensors and a more sophisticated control scheme for 

determining optimal wash water levels. The improved pressure sensor and control logic would 

allow the clothes washer to more accurately determine the load size based on the measured 

volume of water introduced to the clothes container and the transient water pressure measured at 

the bottom of the tub, which is affected by the load size. These controls would reduce excess 

water consumption by filling the wash basket with the minimum volume of water needed to soak 

the load.
5-36

2. Improved Water Flow Control

At EL 2, manufacturers would likely use a combination of electronically controlled 

thermistors and solenoid valves to achieve more precise water flow control. The thermistors 

sense the internal water temperatures, and the control system actively adjusts the solenoid valves 

to maintain the desired internal wash temperature.

3. Spray Rinse

Manufacturers would likely employ a spray rinse at EL 2. Spray rinse significantly 

decreases the volume of water used during the rinse cycle. The clothes washers at the baseline 

level and EL 1 typically use a deep rinse, during which the tub is filled with water to a level in 

which the clothes are submerged, agitated, and then drained to remove soap suds. A spray rinse 

uses high-pressure jets of water to rinse the load while the basket is spinning, without requiring 

the clothes to be immersed.

4. Increased Capacity

At EL2, manufacturers would likely increase capacity slightly by around 0.2 cubic feet 

above the capacity of the baseline and EL1 units.

5. Low-Profile Agitator Design

DOE believes manufacturers would likely move to a low-profile agitator design at EL 2. 

The low-profile agitator design consists of a rotating flat plate at the bottom of the wash basket, 

compared to the standard agitator, which is a finned cylinder that rises axially into the wash 

basket. The low-profile agitator is designed to manually agitate the clothing using less water than 

a traditional agitator in a washer with deep water fills.

6. Improved motor efficiency

At EL2, manufacturers are likely to use a more efficient motor and transmission system 

that reduces the machine electrical energy consumption by almost 50%.

5.6.3.2 Front-Loading Commercial Clothes Washers

Front-Loading Baseline Construction (1.65 MEFJ2 / 5.5 IWF)

DOE is unaware of any front-loading commercial clothes washers currently available on 

the market that are at or above the baseline efficiency level but do not meet EL 1. For this 

reason, DOE established the baseline construction for a front-loading clothes washer at EL 1.

Front-Loading Efficiency Level 1 Construction (1.80 MEFJ2 / 4.5 IWF)

The EL1 front-loading commercial clothes washer is equipped with basic electronic

controls that allow the user to select specific cycle settings, including wash cycle and wash/rinse 

temperature. Typically up to four wash temperature selections are offered, and the temperature is 

controlled using two water inlet solenoid valves combined with a third solenoid to control the 

flow of the mixed water. From the inlet solenoid assembly, the water flows through a detergent 
5-37

dispenser tray before entering the wash basket. The water fill level for a wash cycle is

automatically controlled using a pressure switch. 

The internal tub/drum assembly of the baseline front-loading clothes washer is supported 

by three or four suspension legs attached to a sturdy metal base plate. Two springs attached to 

the upper sides of the outer wrapper may also support the tub/drum assembly from above. The 

tub/drum assembly consists of an internal rotating basket and a stainless steel or plastic outer 

wash tub. The basket is made of a stainless steel cylinder with an attached front ring and back 

plate. Attached to the back plate is a cast aluminum connector piece that secures the drive shaft. 

Molded into the back half of the tub is a cast iron hub that houses two bearings, which guide the 

drive shaft. A variable speed motor powers the drive shaft using a drive belt and drive wheel. 

The motor is attached to the back base plate.

The outer wrapper of the baseline unit typically consists of individual side, back, and top 

panels made of stamped cold-rolled steel (CRS) that are clinched together. The front panel, 

which is a smaller stamped piece of CRS, houses the door assembly. A large piece of tempered 

glass with a plastic frame and handle make up the door assembly, which is attached to the front 

panel by a hinge. A door latch inside the front panel locks the door shut during the wash cycle.

Attached to the front of the internal wash tub is a door seal gasket. This is a flexible ring that 

extends forward from the wash tub to create a water-tight seal when the door is shut.

Based on product teardowns, DOE developed the following baseline production and 

materials cost distributions for a typical front-loading CCW. Table 5.6.6 and Figure 5.6.24 show 

the total cost distribution, and Table 5.6.7 and Figure 5.6.25 show the materials cost distribution. 

Depending on the manufacturer and the production volume, the depreciation costs may vary 

from those shown in the figures, which assume a green-field site.
5-38

Table 5.6.6 Baseline Front-Load Clothes Washer Production Cost Distribution

Cost Category

Total 

Cost 

($2013)

Figure 5.6.24 Production Cost Distribution for Efficiency 

Level 1 Front-Loading Commercial Clothes Washer

Purchased Parts $153.98 

Raw Materials $287.88 

Assy Labor Cost $29.01 

Indirect Labor Cost $40.84 

Fab Labor Cost $3.63 

Supervision Cost $24.25 

Tooling Dep. Cost $74.38 

Indirect Process Costs $52.54 

Equipment Dep. Cost $64.12 

Building Dep. Cost $10.93 

Utility Costs $78.97 

Property Tax $9.51 

Maintenance Costs $7.47 

Insurance Costs $6.70 

Total $844.23

Table 5.6.7 Baseline Front-Load Clothes Washer Materials Cost Distribution

Sub-Assembly

Total 

Materials 

Cost ($2013)

Figure 5.6.25 Materials Cost Distribution for 

Efficiency Level 1 Front-Loading Commercial Clothes 

Washer 

Tub/Drum $142.46 

Control Assy $106.61 

Motor/Pump/Capacitor $59.62 

Outer Wrapper $53.51 

Door Assy $19.76 

Main Wiring Harness $16.45 

Packaging $15.33 

Water Temp Mgmt. $13.45 

Suspension $10.87 

Final Assy $3.81 

Total $441.86
5-39

Construction at Higher Efficiency Levels

Based on the design options retained from the screening analysis (see chapter 4 of this 

TSD), the reverse-engineering analyses, and discussions with manufacturers, DOE developed 

manufacturing costs associated with various design features necessary to achieve higher 

efficiencies. The following are the design changes DOE believes would be necessary to meet 

each higher efficiency level, which were subsequently modeled to obtain incremental 

manufacturing cost estimates.

Front-Loading Efficiency Level 2 (2.00 MEFJ2 / 4.1 IWF)

Based on characteristics of units selected for teardown and based on discussions with 

manufacturers, DOE research suggests that EL2 is typically achieved in front-loading 

commercial clothes washers through the following changes:

1. Reduced Hot Water Temperatures

DOE believes that manufacturers may reduce the temperature of the hot and warm water 

settings compared to the EL1 unit.

2. Improved Fill Level Control

DOE believes manufacturers would use reduced water fill levels compared to the EL2 

unit. The reduction in water fill levels would be achieved through changes to the overall control 

strategy; no hardware changes would be implemented.

Front-Loading Efficiency Level 3 (2.20 MEFJ2 / 3.9 IWF)

DOE research suggests that manufacturers would likely significantly change the design 

platform of a front-loading commercial clothes washer to reach EL 3. A CCW at EL 3 is likely to 

employ the same features as one at EL 1, and would incorporate the following additional 

features:

1. Increased Capacity

At EL2, manufacturers would likely increase capacity by around 0.6 cubic feet above the 

capacity of the EL1and EL2 units.

2. Direct Drive Motor

Manufacturers would likely use a direct drive motor on their front-loading clothes 

washers at EL 3. This would replace the standard variable-speed motor, drive belt, and drive 

wheel used on the clothes washers at lower efficiency levels.

3. Increased Maximum Spin Speed

Manufacturers would likely increase the maximum spin speed for a front-loading clothes 

washer at EL 3. DOE believes the spin speed would be roughly 100 RPM higher than the spin 

speed at EL 1 and EL 2.
5-40

4. Modified Control Scheme

DOE believes that some manufacturers would likely adjust control parameters to improve 

efficiency at EL 3. Through its active mode testing, DOE observed that longer spin cycles and 

lower wash temperature set-points correspond to lower RMC values and less hot water 

consumption, respectively. Neither of these changes is associated with any physical design 

change to the clothes washer, but they may impact consumer utility.

5.6.4 Cost-Efficiency Curves

Based upon product teardowns and cost modeling, DOE developed the following costefficiency relationships for top-loading and front-loading commercial clothes washers.

5.6.4.1 Top-Loading Cost-Efficiency Curves

For top-loading commercial clothes washers, DOE developed incremental manufacturing 

costs by tearing down units, and creating a cost model at each efficiency level. DOE started with 

the baseline unit cost model, and at each higher efficiency level, added in the observed changes 

associated with improving efficiency. By doing this, DOE excluded the costs of any nonefficiency related components from the more efficient units. The more efficient units are 

generally sold at a higher price point, and sometimes include more complex control panels, 

payment options, or other user interface features that are not necessarily efficiency-related. Table 

5.6.8 and Figure 5.6.26 show the incremental manufacturing costs from DOE’s reverseengineering analysis.

Table 5.6.8 Incremental Manufacturing Costs for Top-Loading CCWs Based on MEFJ2

Appendix J2 

Efficiency Level 

Incremental 

Costs ($2013)

Figure 5.6.26 Cost-Efficiency Curve Based on MEFJ2 for 

Top-Loading Commercial Clothes Washer

Baseline

(1.15 MEFJ2 / 

8.9 IWF)

-

EL 1

(1.35 MEFJ2 / 

8.8 IWF)

$0.00

EL 2

(1.55 MEFJ2 /

6.9 IWF)

$39.63
5-41

Table 5.6.8 and Figure 5.6.26 show that the incremental cost to achieve EL1 is $0. This is 

consistent with information gained through product testing and through manufacturer interviews. 

As described above, the design options used to achieve EL1 are control-based strategies that do 

not require any additional hardware costs.

The incremental cost to achieve EL2 is much more significant at $39.63. As described 

above, a more significant design platform change is required to achieve EL2, resulting in 

additional hardware costs over the EL1 design.

DOE is confident in its estimates of the incremental costs for the units it torn down. 

However, DOE is aware that these values are only representative of the small number of units 

torn down, and do not necessarily characterize the entire top-loading commercial clothes washer 

market nor the expected typical costs at the time of the effective date of new standards.

5.6.4.2 Front-Loading Cost-Efficiency Curves

For front-loading commercial clothes washers, DOE tore down units at all efficiency 

levels, except for the baseline level because DOE is unaware of any front-loading CCWs 

available at that level.

DOE observed that manufacturers each have unique EL1 units depending on their 

segment of the market. To account for this, DOE developed incremental cost curves for each 

manufacturer according to their respective product offerings. For a manufacturer only producing

front-loading CCWs at higher efficiency levels, the incremental costs associated with the 

efficiency levels below that manufacturer’s baseline is assumed to be zero. A single costefficiency curve was then calculated from a market share-weighted average of the individual 

curves. The DOE incremental costs shown in Table 5.6.9 and Figure 5.6.27 show the market 

share-weighted average of the incremental cost curves.
5-42

Table 5.6.9 Incremental Manufacturing Costs for Front-Loading CCWs Based on MEFJ2

Appendix J2 

Efficiency 

Level 

Incremental 

Costs ($2013)

Figure 5.6.27 Cost-Efficiency Curve Based on MEFJ2 for 

Front-Loading Commercial Clothes Washer

Baseline

(1.65 MEFJ2 / 

5.2 IWF)

-

EL 1

(1.80 MEFJ2 / 

4.5 IWF)

-

EL 2

(2.00 MEFJ2 / 

4.1 IWF)

$0.63

EL 3

(2.20 MEFJ2 / 

3.9 IWF)

$19.61

Table 5.6.9 and Figure 5.6.27 show that the incremental cost to achieve EL1 is $0, and 

the cost to achieve EL2 is relatively small at $0.63. This is consistent with information gained 

through product testing and through manufacturer interviews. As described above, the design 

options used to achieve EL1 and EL2 are largely control-based strategies that do not require any 

additional hardware costs.

The incremental cost to achieve EL3 is more significant at $19.61. As described above, a 

more significant design platform change is required to achieve EL3, resulting in additional 

hardware costs over the EL2 design.

DOE is confident in its estimates of the incremental costs for the units it torn down. 

However, DOE is aware that these values are only representative of the small number of units 

torn down, and do not necessarily characterize the entire front-loading commercial clothes 

washer market nor the expected typical costs at the time of the effective date of new standards.

$ 0

$ 5

$10

$15

$20

$25

1.6 1.7 1.8 1.9 2 2.1 2.2 2.3 2.4 2.5

Incremental Cost (2012$)

Appendix J2 MEF (cu.ft./kWh/cycle)