Countdown to Compliance
By Ani Jayanth, Manager, Marketing—Foodservice, Emerson
This blog is a summary of the article Countdown to Compliance from our recent edition of E360 Outlook. Click here to read the article in its entirety.
With the Department of Energy’s (DOE) 2017 energy efficiency deadline now visible on the horizon, foodservice OEMs will be the first to feel the brunt of the regulatory storm targeting commercial refrigeration.
For the last several years, the refrigeration industry has been forced to come to terms with a dynamic and often uncertain regulatory environment. On the one hand, the DOE is mandating significant new energy efficiency improvements. On the other hand, the Environmental Protection Agency (EPA) is phasing out the use of widely used high global warming potential (GWP) refrigerants while sanctioning a growing list of acceptable substitutes via its Significant New Alternatives Policy (SNAP) program. The convergence of these two regulatory fronts has created the perfect storm: a once-in-a-generation occurrence that promises to permanently reshape the commercial refrigeration landscape.
This tectonic shift in our industry is creating unprecedented challenges for every segment of the commercial refrigeration supply chain, from OEMs, wholesalers and contractors to design consultants and end users.
Foodservice equipment manufacturers find themselves at the leading edge of this transition. March 27, 2017, is the DOE’s energy reductions compliance date for stand-alone commercial refrigeration equipment — an average of 30–50 percent reductions, as measured in kWh per day. Affected equipment architectures include: remote condensing commercial refrigerators and freezers; self-contained commercial refrigerators and freezers with and without doors, as well as open display cases. This means that all new equipment manufactured after this date fall within the purview of this rule. And with the EPA’s decision to phase out commonly used refrigerants, like R-404A and HFC-134a in 2019, OEMs must factor this key design consideration into their engineering equation.
What’s at stake for OEMs?
One design cycle or two? — When it comes to achieving DOE and EPA regulatory compliance, OEMs face a critical design choice: approach each regulation as a separate engineering effort or combine compliance into a single design cycle.
Compressed design cycle — Regardless of the design cycle decision, OEMs will need to allot sufficient laboratory and testing time to make the necessary design adjustments to achieve DOE compliance and to secure requisite UL, ASHRAE and NSF certifications.
Civil penalties — The details around how the DOE will enforce the ruling remain to be seen, but past performance indicates that they will be prepared to issue civil penalties. After March 27, 2017, equipment manufacturers who are still offering reach-in units that don’t comply with the DOE rule may be subject to these penalties.
Peer scrutiny — As many OEMs will be making significant investments in design changes to achieve compliance, those who are neglecting or avoiding these efforts will likely be subject to the scrutiny of their industry peers. In other words, the industry will also police itself.
Registration in DOE compliance database — It’s important to understand that the DOE maintains a database of commercial equipment for compliance called the Compliance Certification Management System (CCMS). Please see: https://www.regulations.doe.gov/ccms. This database is essentially a record of the baseline energy consumption of equipment prior to making the mandated design changes to achieve new energy efficiency levels. Manufacturers who have not listed their equipment in this database may be subject to civil penalties.
Market pressures — Because design consultants and end users are already seeking refrigeration units that comply with DOE and EPA regulations, OEMs who fail to bring viable products to market may face significant business risks.
The first steps in a larger journey
While many consider the March 27, 2017, DOE deadline on commercial refrigeration equipment the first significant regulatory milestone, it’s important to remember that it’s one of the first steps the industry must take on this journey for compliance. Among the challenges that still lie ahead:
- 1, 2018: DOE new efficiency targets on automatic commercial ice makers
- 1, 2018: EPA delisting R-404A for remote condensing unit architectures
- 1. 2019: EPA begins phasing out R-404A, R-507A, R-410A, R-407A/C/F and HFC-134a in stand-alone units
- 1. 2020: DOE new efficiency targets for walk-in coolers and freezers
There are many miles ahead of us in this journey, and for many in the industry this is uncharted territory. Emerson is committed effectively navigating this shifting regulatory landscape and helping guide the industry toward the next generation of refrigeration technologies and equipment architectures. Through continued collaboration and innovation, we’ll work with you to create systems that are both economically and environmentally viable.