Canada's Energy Efficiency Regulations

Proposed Regulations

Bulletin – August 2007

Residential Dishwashers

Natural Resources Canada's (NRCan's) Office of Energy Efficiency (OEE) is proposing to amend Canada's Energy Efficiency Regulations (the Regulations) in order to strengthen the minimum energy performance standard for residential dishwashers. The upcoming amendment is included in Canada's Clean Air Regulatory Agenda and the accompanying Notice of Intent, as published in the Canada Gazette on October 21, 2006.

This document is intended to inform and seek input from stakeholders on the proposed changes to the regulated criteria for residential dishwashers so that they can submit comments before pre-publication in the Canada Gazette, Part I. NRCan is particularly looking to receive feedback from stakeholders on the proposed minimum energy performance standards. Depending on the nature of the comments received, NRCan may initiate further consultation.

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

Background

The Energy Efficiency Regulations, which came into effect in February 1995, are administered by NRCan. They reference the energy efficiency test standards that must be used to test the products to ensure that they comply with the minimum requirements of the Regulations.

The Regulations include a minimum energy factor (EF) as a performance criteria for residential dishwashers, as well as referencing energy performance test procedures. These performance criteria apply to products manufactured, sold or leased after January 1, 2004. The Regulations reference CAN/CSA-C373-04, Energy Consumption Test Methods and Limits for Household Dishwashers, which was published in June 2004.

CAN/CSA-C373-04 covers standard and compact electrically powered automatic household dishwashers, both built-in and portable. As of January 1, 2004, the dishwashers' annual energy consumption (displayed on the EnerGuide label) has taken into account the standby power consumption and the energy required to heat the water. Soil-sensing dishwashers are also covered by the new testing procedure.

Recently, there have been a number of related activities in North America:

• the BC Ministry of Energy, Mines and Petroleum Resources proposed new standards for various residential products (including dishwashers);
• the US DOE rule-making process was initiated to review the present standard for residential dishwashers;
• ENERGY STAR^® specifications for residential dishwashers were updated, effective January 1, 2007; and
• an agreement was reached between industry (the Association of Home Appliance Manufacturers) and energy efficiency advocates on a proposal for more stringent energy and water efficiency standards for many appliances, including residential dishwashers (announced May 1, 2007).

NRCan is committed to strengthening the Canadian regulatory criteria in order to increase energy efficiency savings, and reduce air emissions and greenhouse gases.

Dishwasher energy performance is commonly characterized by two features, namely:

• EF in cycle/kWh; and
• total annual energy consumption (TAEC) in kWh/year (on EnerGuide label).

Canada's Energy Efficiency Regulations call up the minimum EF levels. The EF is calculated, as per the CAN/CSA-C373-04 standard, as a reciprocal of the total energy per cycle consumed by a dishwasher – including the motor energy during washing, the drying energy during power drying and the energy content of the hot water used – according to the type of controls used (such as truncated dry cycle or heavy, medium and light soil). The calculation also involves statistically determined weighting factors to adjust the energy consumed by type of cycle (heavy, medium or light soil) according to the frequency of use of each type of cycle.

The TAEC is calculated, as per the CAN/CSA-C373-04 standard, as the sum of the annual energy consumption (215 cycles/year x total energy per cycle) and the annual standby energy (energy consumed by the dishwasher while it is not operating or is idle between the wash cycles). Standby energy may be zero for some models, while for others it may be between 15 and 20 kWh per year.

A recent NRCan study indicates that some of the existing dishwasher models with the same EF have a different standby power characteristic, ranging from 0 to 2 watts. As a result, the TAEC for these models varies by up to 4%. The EnerGuide labels display the TAEC which characterizes the actual energy consumption of the dishwashers, not the EF.

Product Description

NRCan is proposing that the Regulations apply to an electrically-operated automatic household dishwasher that is not a commercial, industrial or institutional machine.

Energy Performance Test Procedure

CAN/CSA-C373-04, Energy Consumption Test Methods and Limits for Household Dishwashers, will be the reference test procedure for this product.

Energy Performance Standards

NRCan proposes that the maximum total annual energy consumption (instead of the EF) for standard and compact residential dishwashers will be as follows:

These proposed criteria correspond to EF ≥ 0.62 for standard and EF ≥ 0.85 for compact dishwashers and standby power of 1 watt.

Standby power, also known as "leaking electricity," "vampire power" and "phantom loads," accounts for a significant portion of all electricity used in the typical Canadian home. The proposed changes are in agreement with NRCan's new policy for existing standards and standards in development, and state that standby will be measured as part of energy efficiency test procedures and included in minimum energy performance standards.

This proposed requirement would provide flexibility for manufacturers to find the optimum balance between cycle efficiency and standby losses to achieve the lowest possible total annual energy consumption.

Economic and Environmental Impact

NRCan employed cost-benefit analysis to determine the economic attractiveness of improving the energy efficiency of residential dishwashers. The net present value, calculated by subtracting the present value of incremental costs from the present value of incremental benefits, over the useful life of the product, was chosen as the indicator of economic attractiveness. The base case analysis used a 7% social discount rate, as prescribed by the Government of Canada Treasury Board, and average Canadian residential electricity prices, based on NRCan's official energy supply-demand forecast (Canada's Energy Outlook: The Reference Case 2006). Sensitivity analyses were conducted around the discount rate (5% and 10%) and energy prices (high and low residential electricity prices).

The economic analysis showed positive net benefits for the base case and all sensitivity scenarios for dishwashers. This finding supports the case for new, regulated energy efficiency levels for residential dishwashers.

Effective Date

NRCan is proposing that the energy efficiency standard for dishwashers come into effect on January 1, 2010.

All residential dishwashers subject to the Regulations as described in this document that are manufactured after the specified date will have to meet the stated test requirements and efficiency levels.

Labelling Requirements

Residential dishwashers will continue to be labelled using the mandatory EnerGuide label and voluntary ENERGY STAR^® mark (where qualified). No changes are proposed at this time.

Verification Requirements

NRCan proposes no changes to the verification requirements currently in place for residential dishwashers.

These products will carry a verification mark indicating that the product's energy performance 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 as a verification mark the labels issued by a province indicating that the product meets the provincial energy efficiency levels, provided that the provincial level is equivalent to or more stringent than the federally regulated level.

Reporting Requirements

Energy Efficiency Reports
The energy efficiency report for residential dishwashers will require the reporting of additional information, i.e. annual standby power consumption, and will include the following information:

• test group (built-in or portable; compact or standard);
• volume of water in litres;
• drying options;
• total annual energy consumption in kWh;
• annual standby power consumption in kWh;
• energy factor in cycles/kWh.

The dealer must submit this report to the Minister of NRCan before the product is imported into Canada or traded interprovincially for the first time.

Importing Reports
A dealer who imports residential dishwashers into Canada must include the following information on the customs release document:

• type of product;
• model number;
• brand name;
• 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 regarding the energy performance standards and effective date are harmonized with the recent agreement by industry and energy efficiency advocates, announced on May 1, 2007.

NRCan acknowledges that this agreement also included maximum water consumption limits. Currently, NRCan does not have the authority to set water consumption limits under the Energy Efficiency Act.

Comments Invited

Comments are invited by August 31, 2007. All correspondence should be forwarded to: