Proposed Amendment to Canada's Energy Efficiency Regulations

Bulletin Update - November, 2005

1. automatic defrost refrigerator-freezer, with bottom mounted freezer and through-the-door-ice service (type 5A)
2. chest freezer with automatic defrost system (type 10A)
3. natural compressor cycling auto-defrost system

Natural Resources Canada's (NRCan's) Office of Energy Efficiency (OEE) is proposing to amend Canada's Energy Efficiency Regulations (the Regulations) to harmonize with recent U.S. rulings with respect to automatic defrost refrigerator-freezer, with bottom mounted freezer and through-the-door-ice service; chest freezers with automatic defrost system; and refrigerators with automatic defrost system using natural compressor cycling. The Regulations apply to products imported or shipped interprovincially for sale or lease in Canada.

This bulletin attempts to put the proposed amendment in plain language. The legal text of the amendment will be published in the Canada Gazette, Part I.

BACKGROUND

Energy Efficiency Regulations, which came into effect in February 1995, is administrated by NRCan and references energy efficiency standards that must be used to test the products to ensure that they comply with the minimum requirements of the Regulations.

The Regulations require maximum energy consumption performance criteria for the annual energy consumption limits as well as referencing test procedures that vary with the type and volume of the refrigerator or freezer. These performance criteria apply to products manufactured, sold, or leased after July 1, 2001. The Regulations reference CAN/CSA C300-00: Energy performance and Capacity of Household Refrigerators, Refrigerator-Freezers, and Freezers, which was published in November 2000.

The US DOE has recently issued product exemptions for automatic defrost refrigerator-freezer, with bottom mounted freezer and through-the-door-ice service and for automatic defrost chest freezers, as well as a Direct Final Rule for compact refrigerators using compressor cycling as its automatic defrost. As an interim measure Natural Resources Canada is proposing to amend the regulations directly to harmonize the test procedures in North America. NRCan will also support a revision to the C300-00 standard to be referenced in a future amendment to the regulations.

Automatic Defrost Refrigerator-freezer, with Bottom Mounted Freezer and Through-the-door-ice Service: Currently there is no appropriate defined category for an automatic defrost refrigerator-freezer, with bottom mounted freezer and through-the-door-ice service (as described in the C300-00). The minimum standard for Type 5 (refrigerator-freezers with automatic defrost with bottom-mounted freezer without through-the-door ice service, as described in the C300-00) was established to cover only product without through-the-door ice service at the time of its development.

The actual energy consumption of this new product would likely be higher than that of Type 5 levels due to the added heat loss through the door to the fresh-food space and the energy consumed by the fan used to enhance the convective currents from the actual freezer space to the door space.

On August 11, 2005, the US Department of Energy, Office of Hearings and Appeals, granted an exception for the specific brand automatic defrost refrigerator-freezer, with bottom mounted freezer and through-the-door-ice service (case number TEE-0022). This exception established a maximum energy use standard for this product.

Automatic Defrost Chest Freezer is a chest freezer (a freezer that is accessible from the top) that incorporates an automatic defrost feature. Currently the only appropriate defined category for this product is Type 10 “chest freezers and all other freezers” (as described in the C300-00). The minimum standard for Type 10 was established associated with only manual defrost chest freezers being considered at the time.

While, technically, automatic defrost chest freezer could fit within this product type, typically the energy consumption (due to the frost-free feature) is greater than that allowed for product Type 10.

On September 13, 2004, US Department of Energy, Office of Hearings and Appeals, granted an exception for the specific brand chest freezer with automatic defrost (case number TEE-0012). This exception established a maximum energy use standard for this product. In addition, AHAM filed a letter to the U.S. Department of Energy, Office of Hearing and Appeals supporting this exception and recommending that the U.S. Department of Energy establish a new class of chest freezers that would correspond to the minimum efficiency standard for automatic defrost chest freezers using the Direct Final Rule process.

Compact refrigerators with automatic defrost using normal compressor cycling are made by several manufacturers. These refrigerators have an automatic defrost method that takes advantage of the natural warming of the evaporator during an “off” cycle of the compressor, which saves energy.

The CSA C300-00 definition of automatic defrost contains a (nonmandatory) note that “normal compressor cycling is not considered a defrost system.” A normal automatic defrost refrigerator typically contains electronic controls and a resistance heater, which increase the energy consumption used by the appliance. An automatic defrost appliance that takes advantage of heat recovery from the compressor can be more energy efficient because it does not require as much heating energy in order to defrost the refrigerated and/or frozen volume. It is unclear as to whether this type of refrigerator could be considered manual or automatic defrost.

In March 7, 2003, US. Department of Energy, Office of Energy Efficiency and Renewable Energy published a direct final rule (68 FR 10957) and amended the test procedure 10 C.F.R. 430 allowing the natural compressor cycling to be considered as a automatic defrost system.

NRCan has received positive comments and support from stakeholders and Industry Associations for the inclusion of these new products category in the Regulations.

NRCan’s proposal will ensure that the test procedure and labelling are harmonized for these products in North America.

PRODUCT DESCRIPTION

Automatic Defrost Refrigerator-freezer, with Bottom Mounted Freezer and Through-the-door-ice Service For the purposes of the Regulations, NRCan is proposing to define a Type 5A product which will apply to an automatic defrost refrigerator-freezer, with bottom mounted freezer and through-the-door-ice service.

Automatic Defrost Chest Freezer NRCan is proposing to define a Type 10A product which will apply to chest freezers with automatic defrost system. For the purposes of the Regulations, chest freezer with automatic defrost system means a freezer that is accessible from the top; and, the defrost cycle is automatically initiated and terminated.

Refrigerators and refrigerators-freezers with automatic defrost using normal compressor cycling NRCan is proposing that the Regulations will clarify that products using the natural compressor cycle will be considered an automatic defrost system. This applies to all refrigerators and refrigerator-freezers (including compact).

ENERGY PERFORMANCE TEST PROCEDURE

CAN/CSA C300-00: Energy performance and Capacity of Household Refrigerators, Refrigerator-Freezers, and Freezers, will be the reference test procedure for these products.

ENERGY PERFORMANCE STANDARDS

The maximum annual energy consumption limits for Type 5A automatic defrost refrigerator-freezer, with bottom mounted freezer and through-the-door-ice service; and, for Type 10A automatic defrost chest freezers are:

Type 5A: Annual Energy Consumption Limits = 0.18AV + 539.0
Type 10A: Annual Energy Consumption Limits = 0.52AV + 211.5
where: AV is adjusted volume in liters

The maximum annual energy consumption limits for products with automatic defrost system using natural compressor cycling are as indicated in CSA-C300-00, Table 1, Column B.

EFFECTIVE DATE

NRCan is proposing that the new definition and energy efficiency standard for: Type 5A- Automatic Defrost Refrigerator-freezer, with Bottom Mounted Freezer and Through-the-door-ice Service, Type 10A- Automatic Defrost Chest Freezer and the products with automatic defrost system using natural compressor cycling come into effect immediately upon publication in the Canada Gazette Part II.

All freezer with automatic defrost and all refrigerators and refrigerators-freezers subject to the Regulations as described in this document that are manufactured after the specified date will be required to meet the stated test requirements and efficiency levels.

LABELLING REQUIREMENTS

Type 5A and Type 10A defined products will be labelled using the EnerGuide label for appliances as per the Regulations, PART III.

For products with automatic defrost system using natural compressor cycling no changes to the labelling requirements will be introduced at this time.

VERIFICATION REQUIREMENTS

The same verification requirements that apply to other products regulated under the Energy Efficiency Act will apply to chest freezers with automatic defrost, automatic defrost refrigerator-freezer, with bottom mounted freezer and through-the-door-ice service and refrigerators with automatic defrost system.

These products will carry a verification mark indicating that the energy performance of the product has been verified. The verification mark is the mark of a Standards Council of Canada (SCC) accredited certification organization that administers an energy performance verification program for this product. NRCan will also accept labels issued by a province indicating that the product meets the provincial energy efficiency levels as a verification mark, provided that the provincial level is equivalent to or more stringent than the federally regulated level.

REPORTING REQUIREMENTS

The energy efficiency report required for Type 5A and Type 10A products will include the following information (same as for other freezers):

• type;
• total refrigerated volume;
• adjusted volume;
• annual energy consumption in kWh; and
• freezing capacity of ice in kg/24h.

This report must be submitted, by the dealer, to the Minister of NRCan before the product is imported into Canada or traded interprovincially for the first time.

IMPORTING REQUIREMENTS

A dealer who imports these products into Canada must include the following information on the customs release document:

• Type of product;
• Model number;
• Brand name;
• Name and address of the dealer importing the product;
• Purpose for which the product is being imported (i.e. for sale or lease in Canada without modification; for sale or lease in Canada after modification to comply with energy efficiency standards; or for use as a component in a product being exported from Canada)

HARMONIZATION

NRCan attempts, as much as possible, to harmonize with other regulatory agencies. The proposed amendment to the regulations is harmonized with already accepted levels and standards for chest freezers with automatic defrost, automatic defrost refrigerator-freezer, with bottom mounted freezer and through-the-door-ice service and compact refrigerators with automatic defrost systems in the US:

• US Department of Energy, Office of Hearings and Appeals, case number TEE-0022, August 11, 2005, pp. 1-9 - for automatic defrost refrigerator-freezer, with bottom mounted freezer and through-the-door-ice service
• US Department of Energy, Office of Hearings and Appeals, case number TEE-0012, September 13, 2004. pp. 1-10 - for the frost-free chest freezer
• US. Department of Energy, Office of Energy Efficiency and Renewable Energy. 68 FR 10957; Energy Conservation Program for Consumer Products: Test Procedure for Refrigerators and Refrigerator Freezers, Direct Final Rule. March 7, 2003. p. 10958 - for compact refrigerators with automatic defrost systems.

COMMENTS INVITED

The purpose of this document is to provide stakeholders with background information on the proposed amendment to the Regulations so that they can submit comments during 75 days comment period before proceeding with publication in the Canada Gazette, Part II. All correspondence should be forwarded to: