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Because it's easier to load a box from the top than from the side. For example, consider the upright in post #8 of this thread. See all that empty space in the door? No wasted space like that in a chest fridge.
 

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But the space required to lift them out is wasted unless you find something to put there on top of the other stuff and not fall off. Same issue to a lesser degree on regular shelves with lips. Some designs are worse than others.

I'm just saying this is a factor to consider.

First trip after purchasing my Engel, I made this post:

"this 43-quart (40-liter, 1.4 cu ft) fridge held at one time starting out: 6 soft drinks, a gallon of milk, 6 eggs, 12 sausages, 6 muffins, 7-oz margarine tub, 2 12-oz jars jelly, 4 oz block of cheese, 15 cheese sticks, 8 oz sliced Swiss cheese, a full making of Kraft Mac&Cheese (in two containers), 6 oz meat loaf, about 6 oz ham, a head of lettuce, a green pepper, 4 radishes, 9 oz spinach (1.5 bags not smushed), 4 oz ranch dressing. The fridge was full, but not solidly packed--no special effort needed to make things fit."

Could you fit that in a 1.4 cu ft upright?
 
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