Expert Insights: Step up to new energy-efficiency standards

After nearly a decade of increasing environmental regulations, the U.S. commercial refrigeration equipment supply chain faces an emerging challenge: to prepare for compliance with new Department of Energy (DOE) mandates for reduced energy consumption. 

During the last DOE rulemaking cycle, which began in 2014 and culminated in 2017, original equipment manufacturers (OEMs) responded to the challenge, achieving regulatory compliance — despite compressed timetables and short design cycles. Driven by tightening standards, the next rulemaking cycle — and subsequent sprint to compliance — has begun again.

For the DOE, commercial refrigeration equipment refers to refrigerators and freezers used in supermarkets, convenience stores, restaurants and commercial kitchens. It can either be categorized as self-contained, in which the refrigerated case and the complete refrigeration system are combined into a single unit, or remote condensing, where the compressor and condenser are located remotely from the refrigerated case. Reach-ins are self-contained equipment that have either open or closed cases with solid and/or glass doors. Refrigerated display cases leverage remote condensing and can either have doors or be open cases.

Achieving compliance will require a clear understanding of new efficiency standards and a robust product development process. And unlike the DOE’s last rulemaking cycle, the transition to lower-global warming potential (GWP) refrigerants is now well underway. Complying with these new DOE standards will present significant short- and long-term impacts to system designs. OEMs should begin initiating their new equipment design cycles to test and certify their new product offerings — not only to meet energy-efficiency standards but also to leverage lower-GWP refrigerants.

Part of a regulatory continuum

The DOE’s energy-efficiency regulations on CRE have been in effect for decades. In 2001, the Environmental Protection Agency (EPA) introduced its ENERGY STAR® program to establish voluntary energy consumption guidelines for commercial refrigerators and freezers. These guidelines were then adopted as state law by the California Energy Commission (CEC), outlawing the sale of non-conforming products.

Soon thereafter, the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) adopted a similar energy reduction stance, recommending standards to Congress that were equal to those proposed in California. The resultant Energy Policy Act of 2005 became a federal law in 2010, requiring the DOE to review its national energy-efficiency standards every six years. The most recent DOE Notice of Proposed Rulemaking came out in October 2023, which would require additional energy reductions — effective three years after the final rule.

Many OEMs also voluntarily pursue the EPA’s ENERGY STAR certification to achieve competitive differentiation. The most recent ENERGY STAR standard, Version 5.0, took effect in December 2022. It expanded the equipment scope to include self-contained, medium-temperature (MT) and low-temperature (LT) chef bases (i.e., reach-in units) and self-contained MT service over-counter products and lowered the maximum daily energy consumption in refrigerators freezers. Energy Star is considered the highest level of energy efficiency among regulatory bodies, and often serves as a benchmark for future cycles of DOE efficiency standards. And, when the DOE rule becomes final, look for Energy Star to once again increase its minimum efficiency standards. 

The transition to lower-GWP refrigerants is also playing a role in energy-efficiency considerations and OEM design cycles. Driven by the Kigali Amendment and the passing of the American Innovation and Manufacturing (AIM) Act, the EPA is actively reducing the supply and demand of hydrofluorocarbon (HFC) refrigerants. Its recent Technology Transitions proposal set GWP limits across the spectrum of commercial refrigeration end uses that would phase down the use of legacy HFCs over the next several years.

Equipment design and energy-efficiency considerations

For more than a decade, commercial refrigeration OEMs have worked to meet tightening DOE standards by reducing energy consumption in the MT and LT stand-alone coolers and freezers commonly used in restaurants, C-stores and small-format food retail outlets. Thus far, OEMs have been able to achieve the required incremental energy reductions by making changes within individual components (i.e., fan motors and compressors). The next phase of energy reductions will require OEMs to evaluate efficiencies holistically, considering each component’s contribution to overall system efficiency, such as: doors, lighting, insulation, controls, fans and the condensing unit.

Per its technical support documentation released in June 2022, the DOE recommended many design options for achieving energy-efficiency improvements. Recognizing that each proposed design option would likely come with additional costs, the DOE also provided estimates for how long it might take for energy-efficiency gains to generate a return on investment (ROI).
Previous DOE efficiency standards for reach-in coolers and freezers required 30–50% energy
reductions, measured in kWh/day. 

Because of the wide variety of self-contained, reach-in options, the DOE has proposed a multitude of design levers to help OEMs lower energy usage across the class. Design options and components may be used in a variety of combinations to achieve desired energy reductions. OEMs must determine which configurations make the most sense for specific products in each equipment class.

For example, while increasing the size of condenser coils may help to achieve needed efficiencies without being a significant cost-adder, their impacts on increasing the equipment footprint may make it undesirable in some OEM products. Ultimately, the market may determine which options in the tradeoff between cost and footprint are most favorable.

Start preparing for new efficiency standards

The commercial refrigeration industry is now providing feedback to the DOE regarding the proposed energy-efficiency standard. To prepare for this mandatory requirement, Copeland is helping OEMs to evaluate their design options for improving energy efficiency. If their equipment does not meet the minimum federal energy-efficiency levels upon the rule’s effective date, it will not be allowed to be sold in the U.S.