Proposed Amendment to Canada's Energy Efficiency Regulations

BULLETIN - November, 2004

1 - CHEST FREEZER WITH AUTOMATIC DEFROST SYSTEM; AND
2 - 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 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.

The purpose of this document is to provide stakeholders with background information on the content of the Regulations so that they can submit comments before proceeding with pre-publication in the Canada Gazette, Part 1. NRCan is particularly looking to receive feedback from stakeholders on the proposed new product type - Type 10A, and its minimum energy performance standards, as well as on the proposed changes to the test procedure for refrigerators with automatic defrost system using natural compressor cycling.

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 most recent Canadian standard for refrigerators and freezers (CAN/CSA C300-00: Energy performance and Capacity of Household Refrigerators, Refrigerator-Freezers, and Freezers) was published in November 2000.

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 US DOE has recently issued a product exemption for automatic defrost chest freezers and 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 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, the 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.

NRCan's proposal for this product would be equivalent to the Direct Final Rule in the US.

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 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. In Canada, this type of refrigerator would be considered a Type 11 (manual 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. The amended test procedure resulted in a method that more accurately measures energy consumption and gives credit to the technological advancement of the designing a refrigeration system that no longer has to initiate defrost during a compressor run period, as did the mechanical defrost timers. This amendment also ensures that new products utilizing the new control strategy comply with the applicable energy conservation standards set forth for automatic defrost appliances and are not in violation of the product definition. In the US the same refrigerator would be considered to be Type 13.

NRCan's proposal will ensure that the test procedure and labelling are harmonized for this product in North America.

PRODUCT DESCRIPTION

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.

Compact refrigerators with automatic defrost using normal compressor cycling
NRCan is proposing that the Regulations will consider the natural compressor cycle as a automatic defrost system.

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 both product types. For compact refrigerators with automatic defrost using normal compressor cycling sub-section 5.1.8.4. of C300-00 will be modified as follows:

5.1.8.4 Long-Time Automatic Defrost
If the model being tested has a long-time automatic defrost system, the test time period may consist of two parts. The first part is the same as the time period for the test for a unit having no defrost provision (see Clause 5.1.8.2). The second part starts when a defrost period is initiated during a compressor ON cycle and terminates at the second turn ON of the compressor motor or 4 hours from the initiation of the defrost heater, whichever comes first.

ENERGY PERFORMANCE STANDARDS

Automatic Defrost Chest Freezer
The maximum annual energy consumption limit for Type 10A automatic defrost chest freezers is based on the new exception granted by the U.S. Department of Energy's Office of Hearings and Appeals on September 13, 2004 for this type of product, and is calculated as:

Annual Energy Consumption Limits = 0.52AV + 211.5
where: AV is adjusted volume in liters

Compact refrigerators with automatic defrost using normal compressor cycling
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 for type 13.

EFFECTIVE DATE

NRCan is proposing that the new definition and energy efficiency standard for Type 10A, Automatic Defrost Chest Freezer and the new test procedure for products with automatic defrost system using natural compressor cycling come into effect immediately upon publication in the Canada Gazette Part II.

All chest freezer with automatic defrost and compact refrigerator, 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 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. This product would now be labelled as Type 13.

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 and compact 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, providing that the provincial level is equivalent to or more stringent than the federally regulated level.

REPORTING REQUIREMENTS

The energy efficiency report required for Type 10A product 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 and compact refrigerators with automatic defrost systems in the US:

• 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 - test procedure for refrigerators with automatic defrost system using natural compressor cycling.

COMMENTS INVITED

Comments are invited by December 10, 2004. All correspondence should be forwarded to:

Renata Mortazavi
Senior Standards Engineer
1 Observatory Cres., Building#1,
Ottawa, Ont. K1A 0E4
Phone: (613) 992-5474
Fax: (613) 947-0373
E-mail
http://oee.nrcan.gc.ca/regulations