Manufacturers do not recommend it. However, if you talk to the people, who move washing machines, and sales people, who sell these, they will say it’s fine as long as you drive safely, don’t go over the bumps, avoid any jerk movements and sliding from side-to-side.
Top Loader
If a top loader washing machine is new and not-unpacked, it will have packaging to minimize the drum movement while in transit. So it should be fine to lay it down on its side. DO NOT LAY IT DOWN ON FRONT OR BACK. Download and read the user manual of the washing machine you are going to buy to find out what kind of packaging it might have.
If you read Samsung’s manual of a top loader washer (e.g. WA50M7450AW ), it will ask you to lay it down on its side to remove the cushion support at the bottom of the top loader.
Here are the instructions from Samsung’s top loader’s (WA50M7450AW) manual:
When unpacking the washer, 2 person collaboration is needed. To remove the cushion bottom of the packing materials, forward dumping is strictly prohibited. When you lay the washer down (on its side) to remove carton base, should protect the side of washer and lay it carefully. Never lay your washer on its back or front.
So, according to Samsung, it’s okay to lay down your brand new top loader on its side but not while transporting. So if you think you can transport your still-in-packaging top loader washer laying on its side without going over bumps and without sliding from side to side, so that it is as still as possible, then go for it. You want to avoid inner drums and outer drums from bumping into each other.
Front Loader
If a front loader washing machine is new and not-unpacked, it will have shipping bolts to minimize the drum movement while in transit. It should also have a cushion bottom to prevent drum damage. So it should be fine to lay it down on its side. DO NOT LAY IT DOWN ON FRONT OR BACK. Download and read the user manual of the front loading washing machine you are going to buy to find out what kind of packaging it might have.
Here are the instructions from Samsung’s front loader’s (WF45R6100AP) manual:
You must have at least 2 people unpack the washer. To remove the cushion bottom of the packing materials, do not tip the washer over on its front side. When you lay the washer down (on its side) to remove the carton base, protect the side of the washer and lay it down carefully. Never lay your washer on its back or front.
Conclusion
So, according to Samsung, it’s okay to lay down your brand new not-unpacked top loader or front loader on its side but not while transporting. DO NOT LAY IT DOWN ON FRONT OR BACK. So if you think you can transport your brand new still-in-packaging washing machine laying on its side without going over bumps, without any jerk movements and without sliding from side to side, so that it is as still as possible, then go for it.