ENERGY STAR Program Requirements for Clothes Dryers – Eligibility Criteria 1
ENERGY STAR
®
Program Requirements
Product Specification for Clothes Dryers
Eligibility Criteria
Draft 1 Version 1.0
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Following is the Draft 1 Version 1.0 product specification for ENERGY STAR qualified clothes dryers. A product
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shall meet all of the identified criteria to earn the ENERGY STAR.
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Note: This Draft 1 Version 1.0 specification contains EPA’s proposed ENERGY STAR specification for clothes
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dryers.
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Over the last two years, EPA has actively engaged with stakeholders to discuss efficiency opportunities with
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clothes dryers; these conversations have contributed to the establishment of Advanced Clothes Dryers as one of
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the ENERGY STAR Emerging Technology Award Categories in 2012, the development of the Agency’s Scoping
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Report for Residential Clothes Dryers (released in November 2011),
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the release of a specification development
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launch letter in July 2012, and this first draft of the clothes dryer specification. EPA is appreciative of stakeholder
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contributions to date and encourages feedback from all interested stakeholders on this Draft 1 specification and
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subsequent drafts.
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The note boxes below discuss EPA’s rationale for the proposed program requirements and identify specific topics
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on which EPA is seeking comment. Stakeholder comments are also welcomed on considerations not discussed in
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the note boxes. Please send comments via email to appliances@energystar.gov no later than September 28,
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2012.
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ENERGY STAR Residential Clothes Dryers Scoping Report -
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http://www.energystar.gov/ia/products/downloads/ENERGY STAR Scoping Report Residential Clothes Dryers.pdf
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1) Definitions: Below are the definitions of the relevant terms in this document. Unless otherwise specified,
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these definitions are identical with definitions in the DOE test procedure at 10 CFR 430, Subpart B, Appendix
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D1 or 10 CFR 430.2.
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A. Electric Clothes Dryer: A cabinet-like appliance designed to dry fabrics in a tumble-type drum with forced
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air circulation. The heat source is electricity and the drum and blower(s) are driven by an electric motor(s).
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B. Gas Clothes Dryer: A cabinet-like appliance designed to dry fabrics in a tumble-type drum with forced air
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circulation. The heat source is gas and the drum and blower(s) are driven by an electric motor(s).
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C. Compact size Clothes Dryer: A clothes dryer with a drum capacity of less than 4.4 cubic feet.
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D. Standard size Clothes Dryer: A clothes dryer with a drum capacity of 4.4 cubic feet or greater.
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E. Conventional (Vented) Clothes Dryer: A clothes dryer that exhausts the evaporated moisture from the
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cabinet.
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F. Ventless Clothes Dryer: A clothes dryer that uses a closed-loop system with an internal condenser to
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remove the evaporated moisture from the heated air. The moist air is not discharged from the cabinet.
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1. Water-Cooled Ventless Clothes Dryer: A ventless clothes dryer that uses cold tap water for
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internal condenser cooling.
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ENERGY STAR Program Requirements for Clothes Dryers – Eligibility Criteria 2
G. Commercial Clothes Dryer: An electric or gas clothes dryer that is defined for use in:
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(i) Applications in which the occupants of more than one household will be using the clothes dryer,
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such as multi-family housing common areas and coin laundries; or
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(ii) Other commercial applications.
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H. Combination All-in-One Washer-Dryer: A consumer product designed to clean and dry fabrics in a single
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drum, where a separate drying cycle uses electricity or gas as a heat source and forced air circulation.
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I. Residential Clothes Washer with Optional Dry Cycle: A Residential Clothes Washer that has an optional
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add-on dry cycle, where drying is accomplished through use of electricity or gas as a heat source and
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forced air circulation; drying cannot be selected independently from a wash cycle.
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J. Combined Energy Factor: The quotient of the clothes dryer test load weight in pounds divided by the sum
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of "active mode" per-cycle energy use and "inactive mode" and "off mode" per-cycle energy use in kWh.
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K. Automatic Termination Control: A dryer control system with a sensor which monitors either the dryer load
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temperature or its moisture content and with a controller which automatically terminates the drying
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process. A mark, detent, or other visual indicator or detent which indicates a preferred automatic
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termination control setting must be present if the dryer is to be classified as having an “automatic
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termination control.” A mark is a visible single control setting on one or more dryer controls.
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1. Temperature Sensing Control: A system which monitors dryer exhaust air temperature and
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automatically terminates the dryer cycle.
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2. Moisture Sensing Control: A system which utilizes a moisture sensing element within the dryer
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drum that monitors the amount of moisture in the clothes and automatically terminates the dryer
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cycle.
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L. Basic Model: Units of a given type of covered product (or class thereof) manufactured by one
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manufacturer, having the same primary energy source, and which have essentially identical electrical,
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physical, and functional (or hydraulic) characteristics that affect energy consumption, energy efficiency,
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water consumption, or water efficiency.
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Note: Consistent with recent revisions to other ENERGY STAR appliance specifications, EPA is harmonizing the
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definitions in Section 1 with the definitions in the U.S. Department of Energy (DOE) appliance standards program,
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including the test procedure for clothes dryers located in Appendix D1 of 10 CFR Part 430 or the definitions
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section in 10 CFR 430.2. To this end, the proposed definitions for Electric Clothes Dryer, Gas Clothes Dryer,
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Compact size and Standard size Clothes Dryer, Conventional Clothes Dryer, Ventless Clothes Dryer, Automatic
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Termination Control, Temperature Sensing, Moisture Sensing, and Basic Model are identical to the DOE
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definitions. The proposed definition of Combined Energy Factor (CEF) is also consistent with Section 4.8 of the
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DOE clothes dryer test procedure (Appendix D1).
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EPA also included definitions for several product types that the Agency is proposing to exclude from the scope of
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the Version 1.0 specification. These product types include Combination All-in-One Washer-Dryers and Clothes
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Washers with an Optional Dry Cycle; the proposed definitions for these product types are identical with the
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definitions in the Version 6.0 ENERGY STAR Clothes Washer specification. Similarly, for reasons discussed in
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the Section 2 note box, EPA is planning to exclude Commercial Clothes Dryers and Water-Cooled Ventless
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Clothes Dryers. Since EPA is not aware of existing industry definitions for these product types, the Agency has
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developed a Commercial Clothes Dryer definition by leveraging the existing definition of a Commercial Clothes
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Washer in Version 6.0 ENERGY STAR Product Specification for Clothes Washers and a definition for Water-
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Cooled Ventless Clothes Dryer based on the technical characteristics of this type of product.
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EPA welcomes stakeholder comments on the definitions proposed in Section 1.
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ENERGY STAR Program Requirements for Clothes Dryers – Eligibility Criteria 3
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2) Scope:
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A. Included Products: Products that meet the definition of an Electric Clothes Dryer or Gas Clothes Dryer as
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specified herein and the definition of a consumer product as specified in 10 CFR 430.2 are eligible for
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ENERGY STAR qualification, with the exception of products listed in Section 2.B.
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B. Excluded Products: Commercial Clothes Dryers, Water-Cooled Ventless Clothes Dryer, Combination All-
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in-One Washer-Dryers, and Residential Clothes Washers with an Optional Dry Cycle as specified herein
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are not eligible for ENERGY STAR under this specification.
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Note: In Version 1.0, EPA intends to focus only on residential clothes dryers due to the lack of available energy
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efficiency data on commercial clothes dryer performance. However, as discussed in Section 7, EPA welcomes
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feedback on the potential inclusion of commercial clothes dryers in future specification revisions. EPA is not
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proposing to set a size limitation for clothes dryers eligible for ENERGY STAR qualification in this Version 1.0
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specification with the understanding that specifically excluding commercial clothes dryers based on intended
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application will be sufficient to exclude large, non-residential products.
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As noted in the July launch letter, EPA is proposing to exclude combination all-in-one washer-dryers and
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residential clothes washers with an optional dry cycle from the scope of this clothes dryer specification. EPA is
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also proposing to exclude water-cooled ventless (condensing) clothes dryers from the Version 1.0 specification
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due to the amount of water they use. The Natural Resources Canada estimates water-cooled condensing dryers
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use about 8 to 40 liters/cycle (2 to 11 gallons/cycle).
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Additionally, through initial research, EPA has been unable
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to find any water-cooled condensing clothes dryers being sold in the U.S. Ventless condensing dryers (excluding
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combination all-in-one washer-dryers) appear to mainly use air-cooled condensers with bins for collecting water
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extracted as the load is dried. Since water use is not a concern for air-cooled ventless dryers, EPA proposes to
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include this product type in the Version 1.0 specification.
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EPA welcomes feedback on the proposed scope in Section 2.
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http://oee.nrcan.gc.ca/equipment/appliance/2386
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3) Qualification Criteria:
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A. Combined Energy Factor (CEF): CEF shall be greater than or equal to the Minimum CEF (CEF
M N
) as
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calculated per Equation 1.
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Equation 1. Calculation of Minimum CEF
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where,
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CEF
BASE
is the base CEF, per Table 1
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CEF
Adder_Connected
is the CEF connected allowance, per Table 2
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Table 1: Base CEF
Product Type
CEF
BASE
Vented Gas
3.67
Vented Electric, Standard (4.4 ft
3
or
greater capacity)
4.29
Vented Electric, Compact (240 V)
3.76
ENERGY STAR Program Requirements for Clothes Dryers – Eligibility Criteria 4
(less than 4.4 ft
3
capacity)
Vented Electric, Compact (120 V)
(less than 4.4 ft
3
capacity)
4.15
Ventless Electric, Compact (240 V)
(less than 4.4 ft
3
capacity)
2.93
Table 2: Connected Allowance
Product Type
CEF
Adder Connected
2
All Electric Dryer Types in Table 1
1
0.05 x CEF
BASE
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Product must be qualified using the final and validated ENERGY STAR Test Method (TBD) to
use the allowance.
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Calculated allowance shall be rounded down to the nearest tenth before being applied in
Equation 1.
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B. Drying Time: Dryers must complete drying cycle in < 50 minutes.
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Note: The primary objective of the ENERGY STAR Program is to recognize highly energy efficient products in the
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marketplace. In developing a specification, EPA considers the following Guiding Principles:
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Significant energy and/or water savings can be realized on a national basis;
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Product performance can be maintained or enhanced with increased efficiency;
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Purchasers will recover their investment in increased efficiency within a reasonable period of time;
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Efficiency can be achieved through one or more technologies such that qualifying products are broadly
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available and offered by more than one manufacturer;
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Product energy and/or water consumption and performance can be measured and verified with testing; and
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Labeling would effectively differentiate products and be visible for purchasers.
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For Version 1.0, EPA is proposing minimum requirements for five types of residential clothes dryers. The product
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classes and efficiency metric used are consistent with those expressed in DOE’s 2015 Federal standards for
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clothes dryers. In Sections 3A and 3B, EPA is proposing minimum energy efficiency requirements and maximum
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drying time requirement.
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Energy Efficiency Requirements
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As discussed in the July launch letter, EPA is proposing minimum energy efficiency requirements expressed
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using Combined Energy Factor (CEF). Since a public database with CEF performance is not available, EPA
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developed minimum CEF requirements proposed in Table 1, based on information gathered through research and
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discussions with manufacturers and efficiency organizations on technologically-feasible and cost-effective options
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for improving the efficiency of clothes dryers, also leveraging the work done by the efficiency community over the
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last several years. EPA does not intend to assemble additional data for current models, as discussions with
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manufacturers indicate that products on the market when this specification takes effect will leverage known and
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well tested strategies for delivering efficiency. The Draft 1 proposed levels reflect a 13% reduction in energy use
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from a baseline electric model and a 10% reduction in energy consumption from a baseline gas dryer. The
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Agency has used the amended DOE standards, effective January 1, 2015, as a baseline. The proposed level is
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somewhat lower for the gas dryers because certain cost-effective energy efficient technology options used in
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electric dryers cannot be used in gas dryers (i.e., recycle exhaust heat/recirculation). EPA anticipates a range of
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models could be available and cost effective at that these efficiency levels starting next year.
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ENERGY STAR Program Requirements for Clothes Dryers – Eligibility Criteria 5
To meet the proposed Version 1.0 levels, EPA anticipates manufacturers will mainly employ efficiency options
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such as modulation technology, heat recovery and recirculation, fan and motor efficiency improvements, and
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certain dryer control or drum upgrades (e.g. improved air circulation and modified operating conditions).
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Information available suggests that heat pump and hybrid heat pump technology holds greater savings potential
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but in the near term is expected to have a higher cost premium for consumers; EPA is assuming this technology
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is not necessary to meet the Draft 1 levels.
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Today, an average electric standard size clothes dryer uses approximately 657 kWh/year (as tested under the
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DOE test procedure, Appendix D1). A standard sized electric dryer meeting the proposed Draft 1 requirements
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will save consumers about 83 kWh/year or $153 over an estimated 16 year average lifetime of a clothes dryer. A
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standard size gas dryer meeting the proposed requirements will save consumers about 0.24 MBTU/year or about
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$46 over the product’s average lifetime. Based on these estimates as well as some factors discussed below,
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EPA believes the proposed levels will be cost effective, allowing consumers to recoup their investment within a
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reasonable timeframe.
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EPA believes the above dryer energy use estimates are likely conservative as they do not factor in additional
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energy associated with drying more challenging real-world clothing loads instead of test clothes, and the heating,
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ventilation and air conditioning (HVAC) impacts from clothes dryers, where applicable. Testing results
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summarized in a 2011 Natural Resources Defense Council (NRDC) report indicate that loads intended to reflect
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real-world consumer loads (varying fabric types, load composition, and cloth thickness), require about 35% more
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energy to dry than DOE test cloths.
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This difference is due to the additional time needed to fully dry the more
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challenging real-world load. Given this higher real world energy use, a closer approximation of the annual energy
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use for electric standard clothes dryers may be more on the order of 900 kWh/year; this higher baseline energy
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use substantially increases consumers’ savings from a more efficient dryer. EPA is also aware that additional
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clothes dryer field metering is being conducted and plans to factor in relevant findings as they become available.
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Connected
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EPA has begun to address the opportunities associated with “connected” functionality through several product
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specification revisions over the past year. Consistent with the Agency’s proposals for other home appliances, EPA
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is planning to propose a set of optional connected criteria for residential clothes dryers in Section 4 and has
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proposed a supporting connected allowance in Section 3 for electric dryers. Products that demonstrate they meet
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the connected criteria could opt to use an allowance equivalent to 5 percent of the product’s base CEF
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requirement once their performance is validated using a DOE-developed test procedure for residential clothes
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dryers demand response functionality. This proposal is reflected in Table 2 and Equation 1, above. Prior to the
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development of this test procedure, connected dryers can be qualified as connected through inspection of
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product/product documentation, but will not be eligible for the allowance.
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As in other appliance categories, EPA intends this allowance to serve as a temporary incentive to help jump-start
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the market for connected appliances that provide immediate convenience and energy savings opportunities to
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consumers as well as future-oriented demand response (DR) and price awareness capabilities.
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Drying Time Requirement
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ENERGY STAR Program Requirements for Clothes Dryers – Eligibility Criteria 6
In the launch letter, EPA raised the possibility of including a maximum drying time requirement to ensure that
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energy efficient dryers also meet consumers’ expectations for quick performance, as this is perceived by users as
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the most time consuming laundry task.
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As noted above, one of EPA’s Guiding Principles for ENERGY STAR is
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that product performance be maintained or enhanced with increased energy efficiency. Testing from NRDC’s
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2011 report shows that average drying time for standard electric and gas dryers is around 30 minutes when
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tested with the latest DOE clothes dryer test procedure, Appendix D1; drying times were somewhat longer with a
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real load of 50% synthetic – 50% cotton clothing, and significantly longer with a cotton only load.
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Average drying
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time for one NRDC-tested European heat pump unit was about 60 minutes. Manufacturers have also indicated
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the importance of matching the clothes washer and clothes dryer cycle time. Consumer Reports’ ratings indicate
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that many high efficiency clothes washers on the market in the U.S. have a cycle length (as tested in Consumer
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Reports’ test) of approximately 45-85 minutes.
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After considering these data points, EPA is proposing a maximum
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drying time requirement of 50 minutes, as tested under the DOE clothes dryer test procedure (Appendix D1; see
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Section 5 for additional discussion on testing drying time). In proposing this level, EPA’s aim has been to help
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assure that consumer’s expectations for drying time are met, while also providing a patDoug - hway for advanced
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dryer technologies like heat pump or hybrid heat pump designs, to qualify.
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EPA welcomes feedback on the proposed requirements for residential clothes dryers.
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Denkenberger, D., Mau, S., Calwell, C. and E. Wanless. 2011. Residential Clothes Dryers: A Closer Look at Energy
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Efficiency Test Procedures and Savings Opportunities. Ecova prepared for Natural Resources Defense Council.
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Pescatore, P., and P. Carbone. High Efficiency High Performance Clothes Dryer: Final Report to Department of Energy.
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TIAX. March 2005.
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Denkenberger, D., Mau, S., Calwell, C. and E. Wanless. 2011. Residential Clothes Dryers: A Closer Look at Energy
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Efficiency Test Procedures and Savings Opportunities. Ecova prepared for Natural Resources Defense Council.
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http://www.consumerreports.org/cro/washing-machines.htm
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C. Automatic Termination: In order to encourage the use of energy saving, automatically terminated drying
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cycles, the product shall comply with the following criteria:
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a. The product shall be equipped with automatic termination control that utilizes both moisture and
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temperature sensing controls.
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b. Timed drying cycles, if used, shall:
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i. be limited to a maximum cycle time of 15 minutes, and
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ii. allow mid-cycle adjustment, such that total cycle time exceeds 15 minutes (may be
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implemented as administrator-only functionality)
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Note: EPA is proposing a requirement that ENERGY STAR clothes dryers have automatic termination control that
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uses both temperature and moisture sensing. Automatic termination can save energy by avoiding over-drying
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associated with timed drying cycles.
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Based on research, EPA understands that there are two types of automatic controls found in dryers on the
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market: temperature sensing, and moisture plus temperature sensing. Through manufacturer conversations and
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Internet research, EPA has learned that most dryers currently on the market have temperature sensing controls,
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while only about 20-25% of all dryers also have moisture sensing controls. Consumer Reports has found that
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dryers with a moisture sensor tend to do a better job at sensing when a load is dry (to avoid over-drying a load),
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than dryers with only a temperature sensor.
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Some manufacturers have suggested that moisture sensing
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combined with temperature sensing will maximize the energy savings associated with avoiding over-drying
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clothes after they reach a consumer-acceptable level of dryness. Temperature sensors only detect dryer air
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exhaust temperature and are not able to directly measure the humidity of the air coming out of the drum or the
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actual moisture content of clothes being dried. It is possible for a temperature sensor to shut off the heater at the
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same point for a small, wet load and a large, damp load, if the exhaust temperature for both loads is the same,
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even though the moisture level for each load may differ. One manufacturer has noted that moisture sensors have
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the benefit over temperature sensors of either detecting the humidity in the drum through a semiconductor sensor
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or detecting the dryness of clothes by touching them, through an electrode sensor. EPA also anticipates that
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further innovations to improve the performance of moisture sensing technology could occur, i.e., through
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optimization of the location of an electrode sensor within the dryer drum. EPA has learned that some dryers locate
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ENERGY STAR Program Requirements for Clothes Dryers – Eligibility Criteria 7
these sensors on the drum beams/paddles, as opposed to their traditional stationary location on the side of the
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drum, which could help expose the sensor to a greater assortment of clothes during the drying cycle.
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The DOE test procedure in Appendix D1 does not measure the effects of different automatic termination
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technologies. However, DOE has opened a new clothes dryer rulemaking process to further investigate the
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effects of automatic cycle termination on clothes dryer energy efficiency; EPA is closely working with the
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Department to follow its progress. As an interim step towards recognizing products with improved auto termination
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controls, EPA is proposing that ENERGY STAR qualified dryers also use moisture sensing controls.
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Based on discussions with manufacturer, EPA has learned that there is likely a significant portion of dryer users
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that continue to use timed drying instead of opting for a cycle with automatic termination. Timed drying can often
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lead to over-drying clothes (thus wasting energy and possibly damaging or shortening the lifetime of clothes)
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because the cycle ends at a pre-determined amount of time, rather than stopping based on the clothes reaching
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an appropriate level of dryness. In order to further encourage consumer use of automatic termination, EPA has
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proposed limiting timed-drying option to 15 minutes maximum. This criterion is intended to permit inclusion of
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certain short cycle modes (e.g. wrinkle release or refresh cycles), where the moisture and temperature sensors
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may not need to be used, and the cycle stops at a short, often predetermined amount of time.
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EPA notes that the DOE test procedure requires the use of a timed dry cycle. In order to ensure dryers can be run
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long enough to dry the load to the remaining moisture content (RMC) required by the DOE test, EPA has also
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specified that timed drying cycles permit mid-cycle adjustment so that the total drying time exceeds 15 minutes.
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This functionality may either be exposed to all users or may be protected so that it is accessible to test personnel,
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but not to consumers.
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EPA welcomes stakeholder comments on the proposed drying cycle criteria. EPA also welcomes any data or
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feedback documenting the amount of extra energy use from over-drying attributed to the use of timed drying
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cycles, or consumer behavior patterns for the use of timed drying vs. automatic termination drying.
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1
http://consumerreports.org/cro/clothes-dryers/buying-guide.htm
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D. Warranty Requirements: The product shall have minimum warranties as follows: 3 years parts warranty
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on any control board (microprocesor), and 5 years parts warranty on any sealed system (compressor,
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condenser, evaporator, and all connecting tubing).
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Note: EPA includes warranty or lifetime requirements in ENERGY STAR specifications for a range of different
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product categories, including lighting and HVAC products, water heaters, and roof products. When considering
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whether to address lifetime or warranty in a specification, EPA considers factors such as whether there are known
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performance/quality issues that the Agency needs to consider and address in order to help ensure products meet
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consumers' expectation for efficiency with no sacrifice in performance or quality. The Agency also considers
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whether there are new/emerging technologies involved, where the inclusion of a warranty requirement can help to
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increase consumer confidence and adoption of a new energy-saving technology. For example, EPA currently
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requires manufacturers provide a minimum warranty of 6 years on the sealed system in ENERGY STAR heat
312
pump water heaters.
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EPA believes minimum warranty requirements will help increase consumer confidence in new energy-saving
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clothes dryer technologies, and thus is proposing a minimum 3 year parts warranty for control boards
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(microprocessors) and a 5 year parts warranty on any sealed system that would be used in a heat pump or hybrid
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heat pump clothes dryer. EPA anticipates that ENERGY STAR clothes dryers will need to have control board(s)
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to achieve higher levels of efficiency (i.e., using moisture sensing controls and other advanced controls that
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optimize energy use, air flow, and drying time) than non- qualified dryers. Similarly, EPA believes it is possible
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that heat pump clothes dryers will be introduced in the U.S. and eligible to earn the ENERGY STAR, and that a
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minimum warranty requirement could increase consumer confidence and adoption of this new technology and
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ensure consumer’s expectations for performance and quality continue to be met. To develop the proposed
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requirements, EPA researched the length of parts warranties provided with appliances sold in the U.S.
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ENERGY STAR Program Requirements for Clothes Dryers – Eligibility Criteria 8
EPA welcomes comments on the proposed warranty requirements.
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E. Significant Digits and Rounding: All calculations shall be carried out as specified in Appendix D1 to
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Subpart B of Part 430 and 10 CFR Part 430.23(d).
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F. Model Numbers: Model numbers used for ENERGY STAR qualified product submissions shall be
331
consistent with Federal Trade Commission (FTC) and Department of Energy (DOE) submissions.
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4) Connected Product Criteria: TBD
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Note: As noted in the July 2012 launch letter, EPA is planning to consider connected functionality in the Version
334
1.0 specification. Demand savings for electric dryers can be significant, given they typically draw power on the
335
order of 5 kW during the drying cycle. For this Draft 1 specification EPA has included a placeholder for optional
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connected product criteria. EPA intends to propose specific connected criteria in the Draft 2 Version 1.0 Clothes
337
Dryer specification and encourages stakeholder feedback on connected functionality relevant to clothes dryers.
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EPA is in the process of vetting optional connected product criteria for Refrigerators/Freezers (R/F) with
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stakeholders, through the Version 5.0 R/F specification revision. Similar to what has been discussed for that
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product category, EPA intends to propose connected clothes dryer criteria that enable both near-term consumer
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benefits associated with energy management and added convenience features as well as longer-term, societal
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benefits associated with smart grid interconnection. EPA plans to leverage the latest R/F connected language and
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the recommendations for clothes dryer demand response (DR) functionality provided to EPA and DOE in the
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2010 Joint Petition to ENERGY STAR to Adopt Joint Stakeholder Agreement as It Relates to Smart Appliances.
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In addition to this, EPA is interested in stakeholder feedback as to whether price signals and related consumer
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feedback are of particular importance for clothes dryers given their schedulable nature. EPA believes there may
347
be opportunities for electric dryers to offer additional consumer savings and grid benefits through the ability to
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receive price signals and provide consumers with feedback that encourages operation during favorable pricing
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periods. EPA welcomes suggestions on how to best express this in the specification. More generally, EPA
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welcomes feedback on the Agency’s plan to include optional connected criteria for clothes dryers in the Version
351
1.0 specification.
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5) Test Requirements:
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A. One of the following sampling plans shall be used to test energy performance for qualification to
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ENERGY STAR:
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1. A representative unit shall be selected for testing based on the definition for Basic Model provided
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in Section 1 above; or
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2. Units shall be selected for CEF testing per the sampling requirements defined in 10 CFR § 429.21,
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which references 10 CFR § 429.11.
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B. When testing the energy efficiency of clothes dryers, the following test method shall be used to determine
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ENERGY STAR qualification:
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Table 3: Test Method for ENERGY STAR Qualification
ENERGY STAR Requirement
Test Method Reference
CEF
10 CFR § 430, Subpart B, Appendix D1
1
1
And in accordance with any applicable DOE issued test procedure guidance, listed here:
http://www1.eere.energy.gov/guidance/default.aspx?pid=2&spid=1
ENERGY STAR Program Requirements for Clothes Dryers – Eligibility Criteria 9
Note: The Draft 1 Version 1.0 specification references the latest DOE residential clothes dryer test procedure
362
found in 10 CFR Part 430, Appendix D1, published in January 2011. There are a number of advantages with
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using Appendix D1 prior to the compliance date for DOE regulatory purposes. First, it will enable EPA to maintain
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the Version 1.0 specification change through January 1, 2015, when manufacturers are required to use Appendix
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D1 to demonstrate compliance with the new DOE standards. Related to this, DOE has also published guidance
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that allows manufacturers to use Appendix D1 prior to the compliance date requiring its use (January 1, 2015) to
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rate and certify basic models, as long as certain criteria are met.
1
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The Appendix D1 test procedure also contains updates to testing conditions that better reflect current usage
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patterns, including test load size for standard size dryers, initial RMC, updated annual use assumption, and
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clothes preconditioning. The latest test procedure better represents the product’s total energy consumption since
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it measures standby and off mode energy consumption, included in the energy performance metric, CEF. Finally,
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Appendix D1 includes a method for testing ventless dryers, which will allow testing of efficient ventless designs,
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including, potentially, some heat pump clothes dryers.
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1
DOE 2012 Guidance “Should an amended test procedure be used to rate and certify products prior to the compliance date?”
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http://www1.eere.energy.gov/buildings/appliance standards/pdfs/tp faq 2012-06-29.pdf
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C. Assessment of compliance with Drying Time, Automatic Termination, and Warranty criteria shall be in
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accordance with Table 4.
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Table 4: Test Method for ENERGY STAR Qualification
ENERGY STAR Criteria
Test Method Reference
Drying Time
ENERGY STAR guidance for measuring drying time
during Clothes Dryer Energy Performance Test
(Appendix D1)
Automatic Termination
Examination of product and/or product documentation
Warranty
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Note: Since the current DOE test procedure in Appendix D1 does not measure drying time during the test cycle,
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DOE is planning to develop ENERGY STAR test method guidance for measuring the duration of the drying cycle
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during the DOE test (Appendix D1). The Department plans to provide draft guidance for stakeholder review and
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feedback with the Draft 2 clothes dryer specification.
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EPA proposes manufacturers demonstrate compliance with automatic termination and warranty criteria through
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examination of product and/or product documentation.
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D. Compliance with Connected functionality, as specified in Section 4, shall be through examination of
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product and/or product documentation. In addition, demand response functionality shall be certified using
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the TBD ENERGY STAR test method in order to be eligible for the connected allowance.
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Note: DOE plans to develop a test method to validate the DR capabilities of residential clothes dryers that will be
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referenced in this specification. This test is anticipated to be a separate, add-on test method. Products would
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need to be qualified using this final and validated ENERGY STAR test method to use the proposed allowance.
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In the meantime (prior to when this new ENERGY STAR test method for demand response is available), qualified
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clothes dryers with connected features, as specified in the future Section 4, would be highlighted on the ENERGY
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STAR Qualified Product List.
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EPA and DOE welcome stakeholder comments on the proposed test requirements in Section 5.
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6) Effective Date: The ENERGY STAR Clothes Dryer specification shall take effect on TBD. To qualify for
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ENERGY STAR Program Requirements for Clothes Dryers – Eligibility Criteria 10
ENERGY STAR, a product model shall meet the ENERGY STAR specification in effect on the model’s date of
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manufacture. The date of manufacture is specific to each unit and is the date on which a unit is considered to
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be completely assembled.
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Note: EPA anticipates finishing this specification in spring 2013. Since this is a new specification EPA intends for
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this specification to take effect immediately after it is finalized. For new ENERGY STAR product categories, EPA
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invites manufacturers to qualify and label products as ENERGY STAR as soon as a new specification is finished,
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benefiting industry leaders who are first to offer more efficient products to consumers. In contrast, when revising
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an existing specification, EPA provides a transition period of nine months between when a final specification is
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published and its effective date, to give time for partners to transition any collateral materials to reflect the new
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specification.
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7) Future Specification Revisions: EPA reserves the right to change the specification should technological
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and/or market changes affect its usefulness to consumers, industry or the environment. In keeping with
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current policy, revisions to the specification are arrived at through industry discussions. In the event of a
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specification revision, please note that ENERGY STAR qualification is not automatically granted for the life of
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a product model.
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Note: Appliance manufacturers are required to comply with new Federal standards for clothes dryers beginning
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January 1, 2015. EPA has factored these future requirements into the Draft 1 proposal by citing the new DOE test
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procedure Appendix D1 and by using the 2015 DOE standards as a baseline, so that the ENERGY STAR
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specification does not need to be revised in advance of these forthcoming changes to the minimum standards.
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In addition, to support ongoing discussions with stakeholders on possible future clothes dryer savings
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opportunities, EPA has developed the below list of topics and questions for consideration as the ENERGY STAR
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clothes dryer program evolves in the future.
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Commercial clothes dryers: As noted earlier in the specification, EPA is proposing to exclude commercial clothes
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dryers from the scope of this Version 1.0 specification due to the lack of efficiency data for products currently on
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the market. However, EPA is interested in further information about the energy efficiency opportunity associated
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with commercial clothes dryers. In particular, EPA welcomes feedback on 1) whether there are an industry-
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accepted test method(s) to assess the efficiency of commercial clothes dryers; 2) what is the current baseline
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efficiency or energy use level for commercial dryers; 3) what efficient technologies can be used with commercial
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dryers and their respective energy savings and price; and, 4) market trends in the commercial clothes dryer
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market.
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Eco mode: EPA recognizes “eco mode” (also known as “energy saver mode”) as a potentially significant savings
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opportunity for clothes dryers. Many manufacturers already employ these modes in dryers available for sale in the
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U.S. and have indicated to EPA there has been significant consumer demand for this feature. Eco mode
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traditionally saves energy by reducing power output while lengthening the drying cycle, or stopping the cycle
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before the clothes are completely dry (leaving them damper than a “normal dryness” cycle). Dryers with an eco
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mode may modulate the heater power and fan speed, or employ various algorithms to turn the heater on and off
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at various parts of the drying cycle and efficiently utilize the residual heat in the drum. Alternatively, another
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possible eco mode approach would be to not employ the heater, and use air flow and tumbling action to dry a
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small load of clothes over an extended period of time (possibly overnight). These modes offer savings to users
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who are interested in saving energy by extending the drying time or to those who can tolerate higher moisture
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content for clothes at the end of the cycle.
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Often these eco modes are not the highest heat setting for a dryer cycle, and thus are not a cycle that is
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measured in the DOE test procedure. The 2012 ENERGY STAR Emerging Technology Award for Advanced
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Clothes Dryers includes an eco mode CEF level above the CEF level measured by the highest temperature
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setting in the DOE test procedure.
For purposes of the Emerging Technology Award specification, EPA requires
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eco mode testing using the current DOE test procedure (Appendix D) but with the most energy efficient
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temperature setting (drying mode) rather than the maximum temperature setting. EPA believes there may be
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ENERGY STAR Program Requirements for Clothes Dryers – Eligibility Criteria 11
opportunity to include an eco mode requirement in a future specification revision due to the potentially large
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savings potential (an additional 10% or more) available from this mode. EPA welcomes feedback on 1) what
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proportion of current dryers on the market employ some form of eco mode; 2) the savings potential available from
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these eco modes (using the approach highlighted above from the Emerging Technology Award); 3) consumer
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research that shows the demand for these modes or their use in the real world; and 4) how EPA could implement
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an eco mode requirement in a future specification revision.
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HVAC effects and further research/modeling: Clothes dryers have an associated heating, ventilation, and air
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conditioning (HVAC) impact. Vented dryers take in air from the surrounding room and release heated air through
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an outside vent. The HVAC impact can be greater when the dryer is situated in conditioned rooms where the
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dryer takes in and vents conditioned air to outside the home. The HVAC system subsequently has to make up this
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lost conditioned air from the room. Most ventless dryers use air from the room and release this air at a much
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higher temperature back into the room. DOE estimates in the 2011 Final Rule that the impact of home
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heating/cooling loads on total clothes dryer energy use is about 6% for vented dryers and 11% for ventless
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dryers. The total impact of dryers on home heating/cooling loads will depend on a number of factors (e.g. season,
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climate zone, area in home where dryer resides, dryer technology, home insulation, HVAC equipment, etc.). For
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example, the impact from ventless dryers may be beneficial in the heating season, but will be detrimental in the
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cooling season.
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EPA is aware of ongoing research looking more into the associated HVAC impacts of clothes dryers, and has
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determined that it is too preliminary to address HVAC effects in the Version 1.0 specification. Additionally, the
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DOE test procedure does not measure or estimate a clothes dryer’s HVAC impact. However, EPA remains
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interested in considering this in a future specification revision. One more near-term option could be that EPA
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requires reporting of vent airflow rates for vented dryers, allowing consumers and efficiency programs to estimate
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the amount of conditioned air leaving the room. EPA is interested in feedback on 1) how the HVAC impacts vary
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for different dryer technologies and other factors; 2) any stakeholder research/data that further quantifies a
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clothes dryer’s HVAC impact, or any models used to estimate a clothes dryers HVAC impact; 3) innovative
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designs that are currently being used or are being developed to minimize the HVAC impact of clothes dryers; and,
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4) whether any research has been done to estimate the “standby” HVAC effects of vented clothes dryers (i.e.,
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standby losses through the vent when the dryer is not actively drying clothes); and 5) the value of including a
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reporting requirement of vent airflow rates for vented dryers.
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Additional performance considerations: Fabric care is believed to be important to consumers, demonstrated by
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the fact that some withhold clothes from their dryers from fear of damaging their clothes. Because of this,
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consumers may be interested in purchasing a clothes dryer that is less likely to damage clothes.
2
EPA believes
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that having a minimum drying performance requirement could benefit consumers, but also recognizes that fabric
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care is not easily defined, and that integrating it into the ENERGY STAR specification could add test burden to
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manufacturers. EPA is proposing a maximum drying time or proposal for Version 1.0, but is also interested
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feedback on whether additional performance requirements should be considered for future specifications. EPA is
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interested in consumer data that shows the importance of fabric care/dryer performance, and how EPA might
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implement this requirement in a future specification.
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1
http://www.hydrocarbonconversions.com/hc-heat-pump-dryers-could-meet-eu-efficiency-standards/
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2
Pescatore, P., and P. Carbone. High Efficiency High Performance Clothes Dryer: Final Report to Department of Energy.
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TIAX. March 2005.
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