INTRODUCTION Electrolux is a global leader in household appliances and appliances for ...

107 Pages·2013·1.47 MB·English

DATE 12th April 2013 To: Ros Wallace , DCCEE
FROM Electrolux Home Products Pty. Ltd. <[email protected]>
DEPARTMENT National Quality and Refrigeration Development
SUBJECT AS/NZS4474.2:2013 Draft

INTRODUCTION
Electrolux is a global leader in household appliances and appliances for professional use, selling more than 40 million
products to customers in more than 150 markets every year. Electrolux Home Products Pty Ltd (EHP) is the
Australian operation of Electrolux and employs approximately 1500 people in Australia, including its manufacturing
operations in Orange, NSW and Adelaide, SA.

EHP holds approximately 32% market share in Australia for refrigerators and freezers, with the bulk of these
(approximately 300,000) being manufactured at the plant in Orange. These refrigerators are marketed under the
Electrolux, Westinghouse & Kelvinator brands. The refrigerators range in size from 150 to 700 litres and include Top
Freezer, Bottom Freezer, Single door refrigerators and Freezers, French Door, Side by Side and Chest Freezer
architectures. Orange is the only domestic refrigerator manufacturing operation in Australia, and has been
manufacturing appliances in Orange since 1947.

Globally, Electrolux sells refrigerators and freezers manufactured in Australia, Europe, Asia, Africa and both North
and South America. This is backed up by extensive test facilities in all these areas. We are therefore very familiar
with refrigerator performance requirements in all regions, and support moves to establish a global standard.

OVERVIEW
Electrolux welcomes the opportunity to submit comments and views on the published proposal. Whilst many great
strides have been made for a new standard, MEPS3 proposal, and AS/NZS4474.2:2013 draft, we would like to
highlight some concerns and offer proposals where possible. These are summarized in the bullets below. Electrolux
would also like to mention that these are not exhaustive, but wanted to ensure that key items were submitted by
the 12/4/13 submission date.

 MEPS3 Levels
 Early Adoption of IEC62552
 Additional Testing Regime comparing to current MEPS and labelling as well as US/Canada Testing Regime
 Consumer Sentiment in regards to SRI and labelling from internal/external focus groups
 Current Landscape of SRI Algorithm relating to current registered products and estimate on technical
solutions reaching “Super Stars”, then applying proposed MEPS3 and Paper 7
 Detailed model analysis of the proposed Energy Labelling Algorithm

ELECTROLUX HOME PRODUCTS PTY. LTD.
MAILING ADDRESS TELEPHONE WEBSITE ABN
1 EDWARD STREET, ORANGE, NSW [phone] www.electrolux.com.au 51 004 762 341
2800, AUSTRALIA
TELEFAX E-MAIL ADDRESS
[phone] [email protected]
MEPS3 Levels
We agree with the adjustments to the MEPS3 levels presented at the forum held on March 13th & 14th. We still
believe that the humidity difference between the USA and Australia is relevant to design differences and the impact
on energy but have not had time and/or resources to gather additional data.

Proposal:
Reserve the right to present relevant data at a later data.

Early Adoption of IEC62552
There are clear and known risks involved in being early adopters of a new standard. Australia was an early adopter of
IEC 60335.1:2001 and IEC60335.2.24:2002 (both 1 year later respectively) for electrical approvals which caused
numerous difficulties in sourcing components and onerous certification requirements because no one else in the
world had picked up the new requirements. We do not want a repeat of these problems.

It is well known that issues with a new standard will not be highlighted until it has been in use for a number of
months and by different countries. EHP communicates regularly with Electrolux entities in other economies outside
of Asia Pacific and none of them have indicated an adoption of IEC62552 being tabled. This includes North & South
America, European Union, Middle East and North Africa. While it is acknowledged that Japan may be an early
adopter this is a very specialised and isolated market. They already use a complex test procedure based on dual
ambients and a processing load. The reason Japan are likely to adopt the IEC Standard is that their existing test
procedure is unreliable and largely unrepeatable. That is not the case in Australia where AS/NZS4474 is successfully
used.

If Australia is to be an early adopter, it is very important that Australia’s adoption is orderly, timely, well resourced
and not only be successful, but seen to be successful. This is because the eyes of the world will be on all early
adopters.
Proposal:
Only utilise parts of the IEC62552 that closely mirror AS4474.1:2007. Uncertainty is of concern when applying new
standards. The 3 years implementation period from the approval of the FDIS IEC62552 to introduction of MEPS3 as
proposed at the March Forum should be regarded as a minimum acceptable time frame.

Testing Regime
Currently under AS4474.2:2009 a single energy test is performed at the labeller’s discretion, using 1, 2 or 3pt
methodology, on a minimum of 3 samples. Subsequently, additional performance testing is carried out to ensure
adequate products are registered for sale in the AS/NZ marketplace. Electrolux fully supports the validity of these
tests. Under the proposal there are a series of additional tests for the sole use of energy declaration/star labelling.
Paper 7 proposes that these additional tests, along with calculated adjustment and “normalised” volumes will
provide consumers with a label that is more “realistic” and reflecting of “useful” internal volume.

While Electrolux is completely supportive of providing consumers with the most accurate and meaningful
information, there are several items to consider before undertaking such an endeavour.

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The introduction of a “normalised” volume is seen as an unnecessary complication. “Adjusted” volume is used
globally and should be retained as the default volume for energy efficiency calculations.

The use of 2 ambients for energy testing for interpolation causes a doubling effect on the current testing burden,
and imposes additional logistics for test labs to add one more additional ambient. Laboratories will now require
tests at 10°C, 16°C, 32°C, and 43°C for all registrations. Typical test rooms have capacity to test more than one unit,
and ambient changes require planning to not affect other units under test. Programming lab schedules with an
added ambient will inevitably reduce efficiency further.

Additionally we would like to point out that US/Canada use only 1 ambient (32.2°C) for complete registrations. This
results in a cost advantage for products sold in those countries.

The adoption of the Processing Load from IEC62552 is also an additional testing burden. This testing will by default
cause variation of results and administration due the complex nature and early adoption.

Table 1 below outlines a typical Frost Free product testing plan comparing current method, proposed Paper 7, and
US DOE.
Important points are:

A. The burden of the proposed paper 7 method will more than double the test burden on labs compared to the
current Australian method.
B. The burden compared to the US method is nearly five times.
C. Further equipment investment and personnel will be unavoidable.
D. 3rd party fees will essentially double as well since cost is calculated by utilisation.
E. These costs will undoubtedly be passed on to consumers.
F. Regulator annual output for policing will be halved assuming the same budget.

Note: In the proposed testing below, it should be noted that the IEC62552 60 hour energy verification takes
3 days. Whilst the proposed IEC62552 allows “2 part” energy testing, test labs and manufacturers will be
required to validate that indeed a unit under test can manage the correct defrost intervals for compliance.
Failing to verify this operation cycle can cause registered products to be placed into the marketplace that
defrost more often than stated.

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Table 1

As mentioned previously, Electrolux supports providing consumers with the most accurate, meaningful information
to assist with their best purchasing decision. However, while the MEPS are the legal minimum to register products,
the SRI is also important as indicator for purchasing decisions. Electrolux has concerns that in a competitive
landscape with multi branding marketing being common, the 16°C and 32°C energy testing (along with the impact of
43°C pull down), will cause by virtue a much greater shift to Inverter driver multi-speed compressors. Such
compressors are very costly and suffer from greater warranty costs due to their complexity. This is not to say that
the compressor itself is much more efficient, but that the range of operation which is now being used for labelling
purposes places more emphasis on the 16°C energy test. While good in theory, the average consumer using a
product at the typical ambient of 24°C will not experience a great reduction in energy usage when compared to a
similar COP single speed compressor performance.
Proposal
Unless a clear net benefit case can be made for dual ambient testing, continue with a 32°C only energy test for
MEPS/Label, and remove 16°C & 32°C processing load from the labelling scheme, due to uncertainty and substantial
test burden and product cost increases.

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Consumer Sentiment regarding Labelling
Electrolux has concerns regarding the labelling proposal which is summarised in the comment from Graham Ball,
Senior Category Manager, Electrolux Home Products Pty Ltd, shown below.

“Regarding the effect of previous refrigerator algorithm changes, we have no consumer research specifically on
labelling that I'm aware of. When the last labelling change was made, the feedback was that the change caused
confusion with retailers and consumers. We spent considerable time and effort communicating the changes rather
than working on the next generation of energy efficient appliances.
We created a special section of our Product Connect web site to communicate the changes, created marketing
materials and trained our sales force and call centre operators in the changes. We had requests for new energy labels
even though we kept telling retailers that we could not re-label current stock with new labels. We have a concern
that not every competitor was as diligent in following the spirit and letter of the law in that regard.
Retailers were confused and distracted from their core job of selling appliances. There appeared to be totally
inadequate Government education and communication with Retailers. As whitegoods are by their very nature
durable the changeover of floor stock was very slow. This led to consumers being unintentionally misled that an old
label 4 star product was more energy efficient than a new 3 star product. The consumer may well have a new label
product delivered with the old label product remaining on the shop floor. In fact the incentive for less energy efficient
appliances was not to update floor stock. Therefore the incentives were not in line with the goals of the energy
labelling scheme.
The change to the labels also misled consumers that there had been no improvements in energy efficiency in fridges
even though the industry has been working hard at improving the performance of the products. In fact, Electrolux
was disadvantaged with its range of best in class fridges. We had invested considerable resources into developing a
range of energy efficient fridges and marketed them as 5 and 6 star fridges and then had the impact of that
diminished by the change in star ratings. To rub salt into the wound when TVs had their energy label they often had 5
stars though they consumed more energy than the previous TV technology.
We currently have a scheme that allows for up to 10 stars. The current best fridge is 4 stars. If we change the rating
scheme again it will look like the industry (and the government department responsible) has not been doing anything
to improve energy efficiency with fridges.”

SRI Data mining and Projections

The current labelling scheme released in 2009 has a 23% reduction over the previous star. In addition, 4 additional
“Super” stars were added at that time to prepare the way for future technology advancements. Currently the
MEPS2 levels place the majority of products in the ~2.1SRI. Using projections of the proposed MEPS3 levels, after
taking into consideration the IEC62552 temperature changes of -18°C Freezer & 4°C Food Compartment and wysiwyg
volumes, most products will be placed with an SRI ~1.0 greater than today. This means the average star rating will be
~3.1 SRI on the new label. We believe this is the exact sort of shift that consumers should be expecting as a
progression. Furthermore, that still leaves almost 7 stars for improvement.

The US Department of Energy issues final rulings based on industry data, not only from appliance manufacturers, but
also from the manufacturers that supply industry. These data then allow for projections based on current available
technology as well as component manufacturer’s efficiency progression. We have not seen any such projections
from the Australian regulators. Electrolux believes it is important to understand the impact burden on consumers,
as US DOE states in the FRN091511 final ruling (attached as Appendix A), “the amended energy conservation s
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standards for these products (refrigerator-freezers and freezers) would result in the significant conservation of
energy and are technologically feasible and economically justified”.

Representative Market Example:
A 420L, Group 5T (WTM4200) currently registered is used as an example in Table 2 below. It can be seen that there is
substantial room left to move up the star scale. Current known technology improvements such as Vacuum Panel
insulation, higher COP compressors, motors, etc, will certainly not achieve levels above 6 stars, let alone the virtually
unobtainable 10 star levels. Assuming an average of 10 years between MEPS changes and an average reduction of
25% for each change, based on these assumptions MEPS compliant models with 6 star labels would not be available
for about 30 years.

Table 2
Model: WTM4200WB-R
Energy using
MEPS2 = 517
2009 Gross vol
1 Star 698
2 Stars 538
Current Label 2.5 Stars 456
3 Stars 414
4 Stars 319
5 Stars 245
6 Stars 189
7 Stars 145
8 Stars 112
9 Stars 86
10 Stars 66

Proposal:
In light of consumer sentiment and the adequacy of the current system, continue to utilise the current algorithms in
AS/NZS4474.2:2009 for labelling.

Detailed model analysis of the proposed Energy Labelling Algorithm
Table 3 is a range of our models comparing current MEPS2 to the proposed Energy Labelling Algorithm for 2017. It
assumes new MEPS3 is the 32°C result and the 16°C results use the estimates (Group 1=0.31, Group 5T=0.44 &
Separate FZ=0.51) and processing load based on estimated operating COP of Group 1=1.5 and Groups 4-7=0.8. (As
detailed on page 7 of Household Refrigerators – Energy Labelling Algorithm in Draft AS/NZS4474.2-2013)

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Table 3
MEPS2 MEPS3
BF Published 2010 ERF=0.23 32,16 + proc. proposal 2017 ERF=0.20
4474 4474 62552 Proposed New
MEPS Process
MODEL Total Adj Vol 2010 Total Vnorm LABEL PAEC 16
LABEL Eff.
Gross MEPS Storage PAEC & 32°C
Volume FAF=1.6 SRI fig. (-15/3) Volume 0.8 SRI fig. (-18/4)
Generic 260L 275 327.3 1.087 565.0 245 240.1 68.4 0.846 367.0
WBE5100 505 598.8 1.739 668.7 466 460.9 128.9 0.784 489.7
TF Published 2010 ERF=0.23 32,16 + proc. proposal 2017 ERF=0.20
WTM2800 285 330.4 2.021 460.9 253 239.7 73.2 1.659 305.9
WTE5200 517 589.9 2.494 560.5 479 442.0 141.3 1.310 427.3
SD FZ & Fridge Published 2010 ERF=0.23 32,16 + proc. proposal 2017 ERF=0.20
WFM3000 299 478.7 0.924 629.0 271 271.4 31.2 1.015 372.3
WFM3600 357 571.8 1.005 676.9 330 329.6 37.9 0.950 407.7
WRM3700 368 367.6 0.812 426.9 334 317.7 60.9 1.679 246.8
WRM4300 434 434.0 0.833 450.5 400 381.0 73.1 1.568 269.7
SxS Published 2010 ERF=0.23 32,16 + proc. proposal 2017 ERF=0.20
WSE6070 595.2 737.58 1.085 867.8 552 586.3 142.1 0.764 550.4
WSE6100 606.4 755.5 1.841 743.0 570 611.1 145.0 1.063 525.1
WSE6970 685.2 827.58 1.291 884.0 642 654.0 172.9 0.606 600.9
WSE7000 696.4 845.5 2.027 759.2 656 675.8 174.5 0.888 573.4
Chest Published 2010 ERF=0.23 32,16 + proc. proposal 2017 ERF=0.20
K&WCM1500 145 232.0 2.393 321.2 145 145.0 16.7 2.274 226.0
WCM7000 692 1107.2 2.036 771.1 692 692.0 79.6 0.749 592.0

As can be seen most products end up with SRI value below the MEPS2 SRI with the larger 2 door and chest freezer
models being substantially impacted. The only models to increase SRI are the all fridge models mainly due to the
high operating COP of 1.5. Take for example the TF WTM2800 and WTM5200 the energy goes from 460.9  305.9
(-33.6%) and 560.5  427.3 (-23.8%) respectively yet the SRI reduced by 0.362 and 1.184. Considering the DOE
target energy reduction was ~25% we should expect an SRI increase of ~1.1 stars. The proposal is unacceptable.

Electrolux alternative
The main purpose of the new 2017 MEPS3 is to reduce energy consumption of refrigerators by 10 to 30% in line with
the new DOE requirements. In terms of the new energy label, this energy improvement ideally should be reflected in
both the new kWh/year and the star rating index. This clearly indicates to the consumer that the new MEPS
compliant product is more energy efficient than the MEPS2 compliant older product and by how much.

We propose that the label be based on 32°C testing only (same as the MEPS3 calculation) with the current Cf & Cv
values maintained but the ERF reduces to 0.20. Table 4 show the same range of our models comparing current
MEPS2 to the 32°C only MEPS3.

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Table 4

MEPS2 MEPS3
BF Published 2010 ERF=0.23 Draft MEPS 2017 ERF=0.20
4474 4474 62552 62552
MEPS MEPS
MODEL Total Adj Vol 2010 Total Adj Vol 2017
LABEL LABEL
Gross MEPS Storage MEPS
Volume FAF=1.6 SRI fig. (-15/3) Volume FAF=1.79 SRI fig. (-18/4)
Generic 260L 275 327.3 1.087 565.0 245 298.3 1.898 450.5
WBE5100 505 598.8 1.739 668.7 466 571.4 2.550 544.2
TF Published 2010 ERF=0.23 Draft MEPS 2017 ERF=0.20
WTM2800 285 330.4 2.021 460.9 253 300.3 3.031 351.0
WTE5200 517 589.9 2.494 560.5 479 557.0 3.528 431.4
SD FZ & Fridge Published 2010 ERF=0.23 Draft MEPS 2017 ERF=0.20
WFM3000 299 478.7 0.924 629.0 271 485.8 2.084 489.3
WFM3600 357 571.8 1.005 676.9 330 590.0 2.171 530.5
WRM3700 368 367.6 0.812 426.9 334 333.6 2.100 309.9
WRM4300 434 434.0 0.833 450.5 400 400.0 2.125 328.0
SxS Published 2010 ERF=0.23 Draft MEPS 2017 ERF=0.20
WSE6070 595.2 737.58 1.085 867.8 552 715.7 2.547 615.9
WSE6100 606.4 755.5 1.841 743.0 570 744.4 2.965 573.3
WSE6970 685.2 827.58 1.291 884.0 642 805.7 2.632 645.6
WSE7000 696.4 845.5 2.027 759.2 656 830.4 3.023 601.7
Chest Published 2010 ERF=0.23 Draft MEPS 2017 ERF=0.20
K&WCM1500 145 232.0 2.393 321.2 145 259.6 2.988 295.8
WCM7000 692 1107.2 2.036 771.1 692 1238.7 2.604 724.1

Using the TF WTM2800 and WTM5200 again, the energy goes from 460.9  351.0 (-23.8%) and 560.5  431.4
(-23.0%) respectively, this time the SRI increases by 1.01 and 1.034. As can be seen the 32°C only energy gives a
better fit to the requirement of labels showing reduced kWh/Y and a Star Rating increase in line with the actual 10 -
30% reductions.

MEPS3 Levels
We agree with the adjustments to the MEPS3 levels presented at the forum held on March 13th & 14th. We still
believe that the humidity difference between the USA and Australia is relevant to design differences and the impact
on energy but have not had time and/or resources to gather additional data. However we reserve the right to
present relevant data at a later data.

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Conclusion

We have some major concerns regarding the adoption of the new IEC62552 and AS/NZS4474.2:2013 as presented at
the March 2013 Whitegoods forum.

Firstly, early adoption of an untried and unfinished standard (IEC62552) is a huge design risk for manufacturers.
Risks include:
 New energy target temperatures
 New -18°C maximum pack temperature vs. -15°C for storage tests
 New multiple part energy calculation and defrost intervals
 Uncertainty and repeatability

The 3 years implementation period from the approval of the FDIS IEC62552 to introduction of MEPS3 as proposed at
the March Forum should be regarded as a minimum acceptable time frame.

Secondly, the new proposed energy test method and algorithm raise a number of other concerns.
Concerns include:
 16°C/32°C energy test plus processing load, adds substantial test burden and uncertainty of the results.
 Proposed algorithm does not relay the energy reductions and star rating to the consumer in a positive way.
 23% energy reduction per 1 star improvement is too large.
 New Normalised Volume vs. old Adjusted Volume is unnecessary.

Unless a clear net benefit case can be made for dual ambient testing, EHP suggest continuing with a 32°C only energy
test for MEPS/Label, and remove 16°C & 32°C processing load from the labelling scheme. We believe our alternative
energy proposal at 32°C only which maintain the current Cf and Cv values and only reduces the ERF value from 0.23
to 0.20 meets all of our concerns.

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APPENDIX A

57516 Federal Register / Vol. 76, No. 179 / Thursday, September 15, 2011 / Rules and Regulations
DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket Number EE–2008–BT–STD–0012]
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