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Commercial Refrigeration: Manufacturer’s Guide to the Changing

U.S. Regulatory Landscape

http://www.intertek.com/appliances/commercial-refrigeration/

Commercial Refrigeration: Manufacturer’s Guide to the Changing U.S. Regulatory Landscape

2 www.intertek.com/appliances

Contents

Introduction ........................................................................................................................ 3

Scope of the Commercial Refrigeration Industry ................................................................ 3

New U.S. Efficiency, Refrigerant, and Testing Requirements Impacting the Commercial

Refrigeration Industry ........................................................................................................ 4

New DOE Efficiency Standards for Commericial Refrigeration Equipment:

Direct Final Rule 79 FR 17725 ..................................................................................... 4

New DOE Efficiency Standards for Walk-in Refrigeration: AWEF ................................ 5

New DOE Efficiency Standards for Commercial Ice Machines ..................................... 5

New EPA Standards for Refrigerants: SNAP ............................................................... 6

Rule 20 ................................................................................................................. 6

Rule 19 ................................................................................................................. 6

New Approach to Testing: AEDM ................................................................................. 8

Changes to Testing and Certification Procedures .............................................................. 8

Global Considerations ..................................................................................................... 10

Challenges for Manufacturers .......................................................................................... 10

The Critical Role of Third-party Quality Assurance........................................................... 13

About Intertek .................................................................................................................. 13

Contact Us ....................................................................................................................... 13

APPENDIX ...................................................................................................................... 14




Introduction

The U.S. commercial refrigeration industry is a mature marketplace comprised of many long-

standing competitors who have traditionally focused on drivers such as quality and reliability,

availability and delivery time, total cost of ownership, and meeting the more recent green and

sustainability objectives of their customer base. Based on a host of national, international,

and cultural forces, however, the industry is currently undergoing a regulatory transformation

that will have significant implications on the way commercial refrigeration manufacturers

design, test, and market their products.

Manufacturers of commercial refrigeration systems are facing a changing landscape, from

new energy standards imposed by the U.S. Department of Energy (DOE) and more

environmentally friendly refrigerant alternatives required by the Environmental Protection

Agency (EPA), to the introduction of alternate methods of calculating system efficiency and

simulating the performance of refrigeration units for testing purposes.

Manufacturing compliant products will require a detailed understanding of the new

regulations, the potential incorporation of new materials and/or product designs, and their

adherence to new testing procedures—or facing the risk of being restricted from selling

products that are determined to be non-compliant as of the effective dates of the new

standards.

This white paper provides an overview of the numerous regulatory changes affecting the

commercial refrigeration industry today, discusses the new rules and measures

manufacturers will need to comply with by specific dates in order to continue marketing and

selling their products in the U.S. It also offers insights into the benefits of partnering with an

accredited third-party testing organization to support the all-important testing, submission,

and compliance process.

Scope of the Commercial Refrigeration Industry

The roughly $10 billion U.S. commercial refrigeration industry is comprised of a diverse array

of products,including:

Self-contained refrigeration products

Remote products

Reach-in and walk-in refrigerators and freezers

Commercial ice machines

Vending and custom products




o Note: Any product meant to distribute a beverage through a nozzle (not

bottled), including frozen beverage machines or those that make slushy-type

products, are not specifically included in new regulations, but are expected to

be incorporated moving forward.

According to the DOE, commercial refrigeration equipment is a product used for food storage

and merchandising purposes in the food retail industry (e.g., grocery stores, supermarkets,

convenience stores, specialty food stores, etc.) and the food service industry (e.g.,

restaurants and cafeterias). Any or all of the above products may be impacted by the

following new regulations and rulings.

New U.S. Energy, Refrigerant, and Testing Requirements Impacting

the Commercial Refrigeration Industry

New DOE Energy Standards for Commercial Refrigeration Equipment:

Direct Final Rule 79 FR 17725

Since 2014, the DOE has been extremely active in setting new energy conservation

standards (ECS) in the commercial refrigeration arena, publishing over 100 notices on its

Energy Efficiency & Renewable Energy (EERE) website, issuing more than 25 testing

updates, and enforcing more than 15 final rules that dramatically reduce the energy

consumption of a variety of refrigeration products.

Of greatest importance within the commercial refrigeration

segment is the DOE’s issuance of Direct Final Rule 79 FR 17725

on March 28, 2014, within the Federal Code of Regulations

which will require the Maximum Daily Energy Consumption

(MDEC) requirements in some refrigeration products to be

reduced by as much as 30–60% depending on the product

involved, effective March 27, 2017.

According to the DOE, this Rule “will save approximately 2.9

quads of energy and result in approximately $11.7 billion in

energy bill savings for products shipped from 2017–2046. The

standards will avoid about 142 million metric tons of carbon

dioxide emissions, equivalent to the annual greenhouse gas

emissions of 27 million automobiles.”

With the implementation of

new DOE Direct Final Rule 79

FR 17725, requirements for

Maximum Daily Energy

Consumption (MDEC) in some

refrigeration products must be

reduced by at least 30% and

up to 60%, depending on the

type of product involved.


http://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0003-0104



Because the new MDEC requirements are more stringent than current ENERGY STAR®

thresholds, ENERGY STAR will also have to produce new conservation standards prior to

March 2017 or risk this program not being available for these products in 2017. This may

cause many currently listed products to be removed from its approved list, requiring impacted

manufacturers to potentially undertake research and development and product redesign

activities in order to be compliant with the new regulations.

New DOE Efficiency Standards for Walk-in Refrigeration: AWEF

Within the category of walk-in refrigerators and freezers, which are largely used in the

commercial sector, the DOE has responded to manufacturer concerns regarding the difficulty

of running test procedures for not only refrigeration systems but components (such as the

door and panels) as well by issuing new efficiency standards for walk-ins on June 3, 2014

(79 FR 32049), with an amendement on March 6, 2015. Walk-in

systems are now measured according to the formula, known as

the Average Walk-in Energy Factor (AWEF).

Applicable to walk-in and evaporator products as well as a

variety of condensing solutions (dedicated, multiplexed, etc.), the

resultant efficiency number takes into account the system’s

cooling capacity delivery, power consumption, and insulation and

focuses on the installation and refrigeration elements of the

products.

This new standard is officially moving forward, with the DOE

conducting public meetings with the industry to finalize the

energy conservation standards and applicable dates through the

negotiated rulemaking process. Currently, most of the walk-in

standards appear as though they will not take effect until 2020.

New DOE Efficiency Standards for Commercial Ice Machines

The DOE’s January 2015 Rule (80 FR 4645) also proposes new maximum energy

requirements for commercial ice machines, condensers, and related water usage, with

implementation targeted for January 28, 2018. This efficiency regulation will establish a new

cap on energy consumption and implement energy consumption regulations on “continuous-

type” ice makers (previous regulation only pertained to “batch-type”) that may be challenging

for some manufacturers and will require significant testing and evaluation over the next few

years to understand and verify compliance.

AWEF

Average Walk-in Energy

Factor (AWEF) is calculated

by dividing yearly average

refrigeration output (e.g., how

much cold the unit produces

over a 24-hour period) by the

energy input (e.g., the

amount of energy required to

produce it).

AWEF = yearly average refrigeration output

energy input




New EPA Standards for Refrigerants: SNAP

As a follow-up to its Clean Air Act of 1990, which requires the EPA to “evaluate substitutes

for ozone-depleting substances to reduce overall risk to human health and the environment,”

the EPA created its Significant New Alternatives Policy (SNAP), through which it can

generate lists of acceptable and unacceptable substitutes for each of the major industrial use

sectors and promote a smooth transition to safer alternatives for the affected industries.

In the case of commercial refrigeration, the following two Final Rules, issued in April 2015

and July 2015 (implementation dates per application detailed in appendix), are designed to

minimize contributions to global warming and promote an

environmentally-responsible future:

Rule 20 – “Prohibition on the use of certain high-GWP

HFCs as alternatives”

According to SNAP regulations, “various hydrofluorocarbons

(HFCs) and HFC-containing blends that were previously listed as

acceptable alternatives under the SNAP program are now listed

as unacceptable for specific uses. This rule is part of the SNAP

program’s continuous review of alternatives to find those that

pose less overall risk to human health and the environment.

Specifically, this action changes the listing status for certain

HFCs in various end-uses in the aerosols, refrigeration and air

conditioning, and foam blowing sectors. This action also changes

the status from acceptable to unacceptable for certain

hydrochlorofluorocarbons (HCFCs) being phased out of

production under the Montreal Protocol on Substances that

Deplete the Ozone Layer and section 605(a) of the Clean Air

Act, where substitutes are available that pose overall lower risk

to human health and/or the environment.”

Rule 19 – “Climate-Friendly Refrigerant Alternatives” According to SNAP regulations, the EPA is “providing additional

options for refrigerants in the United States that offer better

climate protection without harming the ozone layer. EPA is listing

certain climate-friendly hydrocarbons (ethane, isobutane, and

propane) and a hydrocarbon blend (R-441A) as acceptable in

EPA’s SNAP Program

According to epa.gov, the

Significant New Alternatives

Policy (SNAP) Program is the

EPA’s program to evaluate and

regulate substances for the

ozone-depleting chemicals that

are being phased out under the

stratospheric ozone protection

provisions of the Clean Air Act.

In Section 612(c) of the Clean

Air Act, the EPA is authorized

to identify and publish lists of

acceptable and unacceptable

substitutes for class I or class II

ozone-depleting substances.

The purpose of SNAP is to

allow a safe, smooth transition

away from such compounds by

identifying substitutes that offer

lower overall risks to human

health and the environment.


http://www3.epa.gov/ozone/snap/regulations.html



stand-alone commercial and household refrigerators and freezers, very low

temperature refrigeration, non-mechanical heat transfer, vending machines, and room

air conditioning units.

EPA is also listing HFC-32 as acceptable in room air conditioning units. HFC-32 has

one-third the GWP of the conventional refrigerants currently being used in room air

conditioning units. Through this rulemaking, EPA is also

exempting ethane, isobutane, propane, and R-441A from the

§608 venting prohibition for the specific applications listed

above."

Overall, while most commercial refrigerant manufacturers in the

industry have historically relied on two popular refrigerant

materials—R-134a and R-404A—manufacturers will no longer

be able to produce units operating on those refrigerants

(implementation dates per application detailed in appendix)

based on their high global warming potential, and are

encouraged/required to pursue more natural refrigerants such as

CO2, ammonia, or flammable materials such as ethane, propane,

and isobutane.

R-134a will still be allowed in some systems, but disallowed for

“self-contained” systems.

This ruling will not only impact refrigeration manufacturers but

their suppliers as well, from whom they will need to source new

refrigerant materials as well as new components such as

compressors.

New refrigerants are expected to emerge including R-448A, R-

449A, and R-450A as replacements for R-134a and R-404A.

However, the actual acceptable use list will be somewhat fluid as

the regulations continue to evolve.

Examples of replacement refrigerants currently being discussed

throughout the industry are outlined below.

Refrigerant Testing

Alternative refrigerants can be

incompatible with existing

system components, and it is

vital to determine the purity of

refrigerants.

Refrigerant testing and

chemical analysis provide

valuable information to help

improve product performance.

Manufacturers should ensure

in-house or third-party testing

meets all analytical provisions

mandated in Clean Air Act

Section 608, tests to the

current ARI-700 standard, the

Industry Recycling Guideline

(IRG-2), and meets the

requirements of ISO/IEC Guide

25 - General Requirements for

the Competence of Calibration

and Testing, which exceeds

requirements in ISO 9002.




Refrigerant Stand-Alone Remote Condensing

Unit Supermarket Rack

Current 404A

134a

404A

407A/F

404A

407A/F

<1,500 GWP

A1 Non-Flammable

450A, 513A

134a, 448A, 449A

450A, 513A

134a, 448A, 449A

450A, 513A

134a, 448A, 449A

<150 GWP

Mildly Flammable

HDR110 HDR110

<10 GWP 290

744

290

744

744

Note: above table merely provides examples of refrigerant replacements currently being discussed in the industry.

Intertek does not endorse any specific replacement as more or less acceptable or effective.

New Approach to Testing: AEDM

While product testing is a critical means of demonstrating a

product’s compliance with performance standards, the testing

process within the commercial refrigeration industry can be

costly and time consuming, and manufacturers have long

complained of the difficulty in building the necessary models on

which to conduct tests. In response to these voiced concerns,

the DOE will allow the use of an Alternative Energy

Determination Method (AEDM), a mathematical model that

simulates the energy comsumption performance of a product line

in a test setting, that will serve to more cost-effectively predict

the product’s performance in the marketplace and enable the

product to be deemed compliant or non-compliant. While this

new approach is expected to increase the speed and efficiency

of the cataloguing process for manufacturers, it may also place

new pressures on manufacturers to create value added AEDMs

and test an appropriate number of products so as to ensure the

validity of the model.

Changes to Testing and Certification Procedures

The following chart provides insights into the way product testing and certification procedures

will likely be impacted by the new efficiency rulings, refrigerant requirements, and

measurement standards in the commercial refrigeration industry:

AEDM Tolerances

Test results from each model

must be compared to

simulated results from the

applicable AEDM. Tolerance

requirements:

For energy consumption

metrics, the AEDM Result for

Model A must be greater than

or equal to the test result for

Model A * 0.95

For energy-efficiency metrics,

the AEDM Result for Model A

must be less than or equal to

the test result for Model A*1.05




How Testing Procedures Will Be Affected by New Efficiency and Refrigerant Standards

System

Type

New Standard or

Approach Effective Date

Key Changes in Testing or Required

Procedures

(including any new evaluation, sampling, and

testing equipment or processes)

Commercial

Refrigeration

Equipment

(CRE)

New DOE Energy

Conservation

Standards (ECS) for

commercial

refrigeration equipment:

Direct Final Rule

79 FR 17725

March 27, 2017 30–60% reduction in allowed energy

consumption.

Walk-In

Coolers and

Freezers

(WICF)

Average Walk-in

Energy Factor (AWEF)

(79 FR 32049)

June 5, 2017

New regulation will likely not take effect until

2020.

Automatic

Commercial

Ice Makers

(ACIM)

New DOE Efficiency

Standards for

Commercial Ice

Machines

(80 FR 4645)

January 28, 2018 ACIMs previously unregulated will now have

maximum prescribed energy limits.

Category not directly impacted by SNAP,

however, component manufacturers may shift

focus to SNAP-friendly models.

No limits set by DOE on potable water use,

but limits are prescribed by ENERGY STAR

should manufacturers seek certification.

MULTIPLE Prohibition on the use

of certain high-GWP

HFCs as alternatives

(SNAP: Rule 20)

April 10, 2015

MULTIPLE Climate-friendly

refrigerant alternatives

(SNAP: Rule 19)

July 20, 2015

MULTIPLE Alternative Energy

Determination Method

(AEDM)

(78 FR 79579)

(79 FR 27387)

Current as of January

2015.

Effective for commercial HVAC, Water

Heaters, and Refrigeration Equipment January

30, 2014.

Effective for commercial WICF February 4,

2054.

MULTIPLE ENERGY STAR No ENERGY STAR

published notices about

these updates.

New 2017 DOE standards are more stringent

than current ENERGY STAR standards. Since

ENERGY STAR typically aims to capture the

part of the market operating at 15% or better

than federal requirements, we expect updates

around the time the DOE standards take

effect. Having the ENERGY STAR Mark will

help drive consumer decisions.


http://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0003-0104



Global Considerations

This white paper focuses primarily on regulatory changes for products being sold within the

U.S. However, there are a variety of additional global regulations impacting commercial

refrigeration products that manufactuers should consider if they plan to export to multiple

markets. Manufacturers should consider engaging with a third-party agency with expertise in

the similarities and differences between various global regulations, then create a plan for

quality assurance and compliance across all target markets. Having a comprehensive

compliance plan prior to product design and launch can create efficiencies in the testing and

certification processes required for market entry.

Challenges for Manufacturers

Manufacturers within the commercial refrigeration industry are currently experiencing a

convergence of paradigm shifts—from requirements to lower their products’ energy

consumption maximums to regulations enforcing the use of more environmentally-friendly

refrigerants, in tandem with numerous new testing procedures to certify compliance. All of

these changes will consume R&D and engineering talent, involve the dedication of additional

time and resources as well as potential investments in product redesign, and require

attention to new testing procedures in order to ensure product compliance by the specific

dates. Manufacturers may need to source new materials, pursue new safety certifications, re-

evaluate pressure limits, reassess their entire manufacturing process, and re-test units to

ensure they have capacity and can manufacture compliant product by the new deadlines.

Beyond all this, as manufacturers grow internationally, in-

depth knowledge of the regulatory requirements of those new

markets is critical. For manufacturers with their own test

facilities, this also requires the capability to test to new

requirements.

As part of a proactive response to these industry dynamics,

manufacturers are encouraged to plan for the changes by

understanding the new standards and procedures required by

each regulatory body, how they apply to their product lines,

and whether their products comply. As the direction and pace

of these federal energy efficiency and environmental changes

is expected to continue, manufacturers are encouraged to get

engaged and participate in industry working groups to help

ensure a smooth, accurate, and executable transition to the

new standards, as well as to proactively plan out the necessary

Manufacturers now need to

consider changing DOE and EPA

requirements, any international

requirements, and unique

requirements for different products.




redesign and certification activities they will need to undertake to ensure that testing labs will

have the capacity to test and certify their new products by the published deadlines.

What is the impact to manufacturer products and processes?

When products and processes are redesigned to accommodate these changes, there are a

variety of considerations and decisions to be made. Crucially, new product components may

require product safety listings to be revised or reissued to allow for the continuation of the

safety certification mark. The introduction of new refrigerants will necessitate changing

components, which will then require both performance and safety evaluation. Incorporating

flammable refrigerants into a manufacturing process requires review of facilities and

processes to consider hazardous location evaluation, detection methods and methodology,

upper and lower explosive limits, emergency stops, electrical power, area and exit lighting,

visual markings, air change, operational procedures, employee training plans, personal

protective equipment (PPE), shipping and handling, and hazardous materials certification.

The below graphic highlights some key considerations manufacturers may need to address.

Redesigned Products

Need to Validate

Performance Compared to Regulations

Testing or AEDM or both

Need to Publish Data

to DOE Website & Manage Program

Process to Handle

Verification Issues

Redesigned Products

Need Safety Certification

New components

mean product listings need to be revised or

reissued

Redesigned Processes

Facility and Processes Need to be

Evaluated as Hazardous Locations

Flammable refrigerant products

require HazLoc evaluation due to the potential of an explosive

atmosphere (including S&H)

Operational & Staff

Training Changes

Detection methods,

explosive limits, emergency

stops, electrical power, lighting, exit lighting, air change, PPE & training plans

Use a Third Party or Do It Yourself?




The Critical Role of Third-Party Quality Assurance

The dynamic U.S. market for commercial refrigeration is undergoing a multitude of changes

designed to enhance the energy efficiency and environmental friendliness of products as well

as streamline testing procedures. The ability for a manufacturer to certify that products

comply with all relevant energy, performance, and environmental standards will help to meet

sales targets, assure end users that products are qualified for specific applications, and

deliver manufacturers marketing and competitive advantages. Because specific standards

and submission procedures can be very tedious and precise to administer, but are critical to

a company’s growth and sales objectives, manufacturers may choose to partner with a

skilled third-party quality assurance organization with expertise in standards development,

testing, and compliance processes to ensure maximum success.

Accredited third-party quality assurance and testing organizations like Intertek can help take

the guesswork out of the successful achievement of compliance. A test lab’s possession of

and investment in the most precise and capital-intensive testing equipment ensures

consistent testing procedures and accurate results, while demonstrated expertise in the

unique details and requirements of all industry certification programs and initiatives assures

manufacturers of the utmost in quality coverage and representation. Along with established

relationships with all of the industry’s key regulatory organizations, a third-party testing lab’s

understanding of and experience with the broad range of products, standards, and testing

procedures in the rapidly-evolving commercial refrigeration industry can proactively support a

manufacturer’s compliance while delivering security and peace of mind to both

manufacturers and customers alike.

Intertek’s Unique Value to Manufacturers

Intertek can help you navigate these changes in many ways, including:

Product Design for Safety, Performance, and Manufacturability

Test Facility Building or Improvement Assistance

o Incorporating current and future planned changes to regulatory requirements

and for new environmentally friendly refrigerants

Employee Training

Testing Expertise and Capacity

AEDM Development Assistance

Contract Manufacturer Integration

Program Management

Get on-demand expertise to accelerate product design and market launch, access global

markets, reduce costs, and mitigate risks. By combining worldwide testing facilities and

experts with an industry-leading breadth of consulting services, Intertek offers a unique




partnership approach to managing quality assurance. Our clients leverage our expertise in

quality assurance and regulatory compliance to allow their teams to focus on core

competencies and business growth.

About Intertek

Intertek is a leading quality solutions provider to industries worldwide. From auditing and

inspection, to testing, training, advisory, quality assurance and certification, Intertek adds

value for its customers by helping improve the quality and safety of their products, assets

and processes. With a network of more than 1,000 laboratories and offices and over 42,000

people in more than 100 countries, Intertek supports companies’ success in the global

marketplace, by helping customers to meet end users’ expectations for safety, sustainability,

performance, integrity and desirability in virtually any market worldwide. Visit

www.intertek.com.

Contact Us

If you would like to connect with an expert to answer your technical questions or obtain a

quote for a new testing project, contact Intertek at 1-800-967-5352 (1-800-WORLDLAB),

email [email protected], or visit our website at www.intertek.com/appliances.

This publication is copyrighted by Intertek and may not be reproduced or transmitted in any form in whole or in

part without the prior written permission of Intertek. While due care has been taken during the preparation of this document, Intertek cannot be held responsible for the accuracy of the information herein or for any consequence

arising from it. Clients are encouraged to seek Intertek’s current advice before acting upon any of the content.


http://www.intertek.com/

mailto:[email protected]




APPENDIX

Tables sourced from EPA’s Significant New Alternatives Policy (SNAP) Program Fact Sheet, published July 2, 2015.

Table 1: SUMMARY OF SECTORS MODIFIED BY THE FINAL RULE




Table 2: FOAMS




Table 3: RETAIL FOOD REFRIGERATION




Table 4: VENDING MACHINES


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