Complying with the
FTC's Appliance Labeling Rule
Introduction
This booklet summarizes the lamp
labeling requirements of the Appliance Labeling Rule (the
Rule) to help you comply with the package labeling,
catalog, and point-of-sale disclosure rules for general
service incandescent lamps (reflector and non-reflector),
medium screw base compact fluorescent lamps, and general
service fluorescent lamps. The booklet answers
commonly-asked questions and includes the lamp labeling
requirements.
The explanations in this publication
refer to the cited sections of the Rule. You will find
additional information in the statement of basis and
purpose for the Rule, 59 Fed. Reg. 34014 (1994). The lamp
labeling requirements were mandated by the Energy Policy
Act of 1992 amendments to the Energy Policy and
Conservation Act of 1975, 42 U.S.C. 6201, 6291-6309.
Although the Rule became effective May
15, 1995, the FTC delayed enforcement for incandescent
lamps until December 1, 1995.
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What
Are the Requirements
The Rule requires that packaging for
three types of lamps general service incandescent
(including both reflector and regular light bulbs),
medium screw base compact fluorescent, and general
service fluorescent include specific information
to help consumers buy the most energy-efficient lamps for
their needs. The Rule also requires the manufacturers,
distributors, and retailers of these products to include
certain disclosures in catalogs consumers use to order
the products, and in certain point-of-sale written
materials.
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Who
Must Comply
The Rule applies to those who:
- manufacture, private label,
import, distribute, or sell covered lamp products
to retail consumers
- prepare printed material about
covered lamp products for display or distribution
at the point of retail sale
- display or distribute printed
material about covered lamp products at the point
of retail sale
- promote covered lamp products in a
catalog from which retail users (consumers) can
order them.
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What
Products are Covered
Section 305.3(k)-(m) of the Rule refers
to the following covered products or covered
lamp products.
Incandescent Lamps
For purposes of the Rule, the term general
service incandescent lamps includes: (1) nonreflector
incandescent lamps (including tungsten-halogen lamps)
that have a rated wattage of 30 or higher, an E26 medium
screw base, and a rated voltage or voltage range at least
partially within 115 and 130 volts; and (2) reflector
lamps (other than colored lamps or those designed for
rough or vibration service applications) that contain an
inner reflective coating on the outer bulb to direct the
light, an R, PAR, or similar bulb shape (excluding ER or
BR), a rated wattage of 40 or higher, an E26 medium screw
base, a rated voltage or voltage range at least partially
within 115 and 130 volts, and a diameter exceeding 2.75
inches.
See section 305.3(m)(2)-(3) of the Rule
for the specialty-type incandescent lamps that are
excluded from the Rule.
Medium Screw Base
Compact Fluorescent Lamps
The Rule covers only compact
fluorescent lamps that are integrally ballasted, with a
medium screw base and a rated input voltage of 115 to 130
volts. This type of compact fluorescent lamp is designed
to replace a general service incandescent lamp.
The Rule covers four kinds of general
service fluorescent lamps:
- Straight-shaped lamps with a rated
wattage of 28 or more
- U-shaped lamps 22 to 25 inches
long with a rated wattage of 28 or more
- Eight foot long rapid start lamps
of 0.800 nominal amperes
- Eight foot instant start lamps
with a rated wattage of 52 or more
See section 305.3(k)(2)-(3) of the Rule
for the kinds of fluorescent lamps that are excluded from
the Rule.
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How
to Comply
Required Labeling for
Covered Products
Section 305.11(e) of the Rule
defines the labeling requirements. All disclosures must
be made clearly and conspicuously, but no type size or
style is prescribed for the required information. See
Appendix L of the attached Rule for examples of
acceptable label formats.
General Service
Incandescent Lamps
The following information must
appear clearly and conspicuously on the product
packages principal display panel:
- The number of lamps included in
the package, if more than one.
- The design voltage of the lamps,
if it is other than 120 volts.
- The light output of each lamp
included in the package, expressed in average
initial lumens.
- The electrical power (energy used)
of each lamp included in the package, expressed
in average initial wattage.
- The life of each lamp included in
the package, expressed in hours.
The terms light output, energy used,
and life must be used and must appear in
that order and with equal clarity and conspicuousness.
In addition,
- The light output, energy used, and
life ratings must be listed in terms of lumens,
watts, and hours, respectively.
- Each of the lumens, watts, and
hours rating numbers must appear in the same type
style and size.
- The words light output, energy
used, and life must appear before and
be as conspicuous as the rating numbers and the
words lumens, watts, and hours.
- The letters of the words
lumens, watts, and hours must be about
half the size of the letters used for the words, light
output, energy used, and life,
respectively.
For incandescent lamps that operate
with multiple filaments, the light output and wattage at
each level of operation and the lamps life,
measured on the basis of the filament that fails first,
must be disclosed.
These disclosures must be based on the
operation of the lamp at 120 volts, regardless of the
lamps design voltage. If the lamps design
voltage is not 120 volts, each disclosure of light
output, wattage, and life must be followed by the words at
120 volts.
The following statement also must
appear on the principal display panel of the package:
To save energy costs,
find the bulbs with the light output you
need, then choose the one with the lowest
watts.
Compact Fluorescent
Lamps
The required disclosures for
general service incandescent lamps must be on package
labels of medium screw base compact fluorescent lamps as
well.
For these products, light output must
be measured at a base-up position. If the manufacturer or
private labeler believes that the light output at a
base-down position would be more than five percent
different, the light output at the base-down position
also must be stated on the label. If no test data for the
base-down position exist, the fact that the light output
might be more than 5 percent different at a base-down
position must be stated.
Incandescent Reflector
Lamps
Labels for incandescent reflector
lamps (spotlights and floodlights) must have the same
disclosures as those required for general service
incandescent lamps and medium screw base compact
fluorescent lamps. However, the light output for an
incandescent reflector lamp must be given for the
lamps total forward lumens.
The statement about saving energy costs
must be included on incandescent reflector packages. This
statement may include language about beam spread,
but this portion of the disclosure is voluntary:
To save energy costs,
find the bulbs with the [beam spread and]
light output you need, then choose the one
with the lowest watts.
The label for incandescent reflector
lamps must contain the capital letter "E"
printed within a circle, followed by an asterisk (*) and
this statement:
* means this bulb
meets Federal minimum efficiency standards. If that
statement is not made on the principal display panel, the
asterisk must be followed by this statement:
*See [back, top, side] panel for
details.
General Service
Fluorescent Lamps
The label for general service
fluorescent lamps must contain the capital letter
"E" printed within a circle, followed by an
asterisk (*). The label must include the following
statement:
* means this bulb
meets Federal minimum efficiency standards.
If that statement is not made on the
principal display panel, the asterisk must be followed by
this statement:
*See [back, top, side] panel for
details.
If a manufacturer or private labeler
does not package or put labels on general service
fluorescent lamps, these disclosure requirements can be
met by permanently marking the lamp with the .
The must appear in
color-contrasting ink and it must appear in a typeface as
large as either the manufacturers name or logo or
another logo disclosed on the label, such as the UL,
CBM, or ETL logos.
It is not necessary for the labels
for general service fluorescent lamps to include the
disclosures that are required on labels for incandescent
and compact fluorescent lamps.
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Requirements
for All Cartons of Covered Lamp Products Shipped within
our Imported into The U.S.
Section 305.11(e)(4) of
the Rule requires the following statement on cartons of
covered lamp products that are shipped within or imported
into the U.S.:
These lamps comply with
Federal energy efficiency labeling requirements.
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Requirements
for Promotional Materials Displayed or Distributed at the
Point of Sale
Section 305.13(a)(3) of the Rule
includes additional requirements for manufacturers,
private labelers, importers, distributors, or retailers
who prepare printed material for display or distribution
at the point of sale.
If a representation is made about the
cost to operate a covered lamp, information must be
provided about how the figure was determined. This
information may include purchase price, unit cost of
electricity, hours of use, and patterns of use. These
disclosures must be clear and conspicuous on the printed
material near the representation about the cost of
operation.
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Requirements
for Catalogs
Section 305.14(c) of the Rule details
the disclosure requirements for lamp products sold
through catalogs; section 305.2(m) defines catalog.
Each page of a catalog that lists a
covered compact fluorescent lamp or general
service incandescent lamp (reflector and
non-reflector) must include all the information required
on the package label except the number of units in
the package. This includes the disclosures of light
output, energy used, life, and the design voltage, if it
is other than 120 volts.
The following information must comply
with the format provisions of section 305.11(e)(1)(ii):
- the light output, energy used,
and life disclosures must appear together
in the catalog, in that order; they must be
equally clear and conspicuous;
- the light output, energy used,
and life disclosures must be made in terms
of lumens, watts, and hours, respectively;
- the lumens, watts, and hours
rating numbers must appear in the same type style
and size, and each of the words lumens, watts,
and hours must appear in the same type
style and size; and
- the words light output, energy
used, and life must precede and be as
conspicuous as both the rating numbers and the
words lumens, watts, and hours.
However, the letters of the words lumens,
watts, and hours must be approximately
half the size of those used for the words light
output, energy used, and life,
respectively.
The disclosures do not have to comply
with these format requirements if the catalog is not
distributed to consumers who are making purchases for
personal use.
For all types of catalogs:
- On each page that lists a covered general
service fluorescent lamp or an incandescent
reflector lamp, the required by section
305.11(e)(2) must be disclosed like this:
- The
must appear with each lamp entry and
- The statement about the
meaning of the
must appear at least once on the page.
- If the catalog contains
representations about the cost to operate a
covered lamp product, it must provide
information about how the cost was
determined. This information may include
purchase price, unit cost of electricity,
hours of use, and patterns of use. These
disclosures must be made clearly and
conspicuously and must be placed close to the
operating cost representation.
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Testing
and Sampling Requirements
Manufacturers or private labelers must
test samples of their products as the basis for the
required disclosures, using certain procedures. Section
305.5(b) of the Rule details the testing requirements.
The following disclosures must be
supported by competent and reliable scientific tests:
- For covered medium screw base
compact fluorescent lamps and general service
incandescent lamps (both reflector and
non-reflector lamps), disclosures of design
voltage, wattage, light output, and life.
- For covered general service
fluorescent lamps and incandescent reflector
lamps, the .
The Rule does not require the use of
specific test procedures, but section 305.5(b) lists
certain test protocols that the FTC will accept.
You must use competent and reliable
scientific sampling procedures to choose samples for
testing. The sampling requirements for selecting test
specimens are included in section 305.6(b) of the Rule.
- The Rule does not require use of a
specific sampling procedure, but section 305.6(b)
states that the FTC accepts "Military
Standard 105 - Sampling Procedures and Tables for
Inspection by Attributes."
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Record
Keeping Requirements
Section 305.15(a) requires that
manufacturers and private labelers keep records for two
years after production of the specific lamp product has
ended. These records must show a reasonable basis
consisting of competent and reliable scientific tests
for the accuracy of the required disclosures on
labels and in catalogs.
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Submission
of Test Date Records
Section 305.15(b) requires that a
manufacturer or private labeler submit to the Commission,
within 30 days of a request from the Commission, the test
data supporting the required disclosures.
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Supplying
Specimens for Testing By a Laboratory Designated by the
FTC
Section 305.16 requires that, if the
FTC requests, a manufacturer of a covered product must
supply up to two models of each lamp product to a
laboratory chosen by the FTC to determine whether the
disclosures comply with applicable standards. The FTC
will pay for this testing. This process would occur only
after the FTC examined the supporting test data provided
by the manufacturer, as required by section 305.15, and
after the manufacturer has had a chance to replicate test
results.
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Questions and Answers
The following questions and answers may help you comply with the Rule:
Q: Does the Rule require that the disclosures be made on
labels in a specific type size or print style?
A: No. The Rule does not specify type size or style of print for
the required disclosures. However, it does require that the information be disclosed
clearly and conspicuously, in a certain order, and according to a specific relative size
relationship. For general service fluorescent lamps, the Rule has two additional
requirements. First, the
must appear on the label in color-contrasting ink. Second, it must appear in a typeface at
least as large as the largest logo on the label, whether its the manufacturers
name or logo or another logo, such as the UL, CBM, or ETL logos.
Q: Where must the disclosures appear on the product package?
A: The basic disclosures must appear on the principal display
panel the main location for information on the product package. However, certain
disclosures may be made on a side or back panel if that location is noted clearly and
conspicuously on the principal display panel.
Q: Does the Rule require that the disclosures on the package be
included inside a lined box or boxes on the principal display panel, as shown in the
illustrations in the Rule?
A: No. The illustrations included in the Rule, which show the
disclosures inside lined boxes, are just examples of permissible disclosure formats.
Q: Does the Rule permit the listing of the lamps lumens, watts,
or hours on the principal display panel in addition to the required
"side-by-side" or "in the specified order" disclosures?
A: Yes. If the manufacturer includes the required disclosures of
light output (in lumens), energy used (in watts), and life (in hours) on the principal
display panel in the order and manner required by section 305.11(e) of the Rule, the
manufacturer may include one or more additional disclosures of any of those individual
items on the principal display panel, or on other panels of the package. The additional
disclosures need not be accompanied by all other required items each time they appear.
However, the additional disclosures must appear as clearly and conspicuously as the
required or principal disclosures. Whether they are made clearly and conspicuously is a
factual question that will depend on factors such as if the separate disclosures are made
in the same type style and size as the required disclosures, the print background colors,
and the number of times the separate disclosures appear.
Q: Does the required disclosure of the apply to compact fluorescent lamps?
A: No. The disclosure
applies only to lamp products for which there are Federal minimum energy efficiency
standards: specified general service fluorescent lamps and incandescent reflector lamps.
Q: May a manufacturer of private labeler add information on
the product label about light output, energy used, or life of an incandescent lamp at a
design voltage other than 120 volts?
A: Yes. The Rule requires manufacturers and private labelers of
incandescent lamps to disclose light output, energy used, and life of the lamp when it is
operated at 120 volts, regardless of the lamps design voltage. However,
manufacturers and private labelers may include the additional disclosures of the
lamps light output, energy used, and life when it is operated at a design voltage of
125 volts or 130 volts. These additional disclosures must include the voltage at which
they apply (for example, Light Output 1710 Lumens at 125 volts), and they may appear on
any panel of the package. If they appear on the principal display panel, the manufacturer
or private labeler may make the required disclosures for operation of the lamp at 120
volts on a side or back panel. However, this option imposes the following requirements:
- All panels of the package that claim light output, energy used, or life
must identify the lamp as "125 volts" or "130 volts" as appropriate;
and
- The principal display panel must include the following statement clearly
and conspicuously:
This product is designed for [125/130] volts. When used on the normal
line voltage of 120 volts, the light output and energy efficiency are noticeably reduced.
See [side/back] panel for 120 volt ratings.
Q: Does the Rule require disclosures in advertisements?
A: The Rule requires disclosures on labels and catalogs, and on
point-of-sale materials that make cost of operation claims. The Rule does not require
disclosures in advertisements and other promotional material. However, if an ad refers to
the energy used or the efficiency of a lamp product for which the Department of Energy has
prescribed a test procedure under section 323 of the Energy Policy and Conservation Act,
the ad would be considered a violation of section 5(a)(1) of the FTC Act (unfair or
deceptive act or practice) unless the advertised product has been tested properly and
unless the ad fairly discloses the test results. Section 305.4(d) of the Rule states
the requirements for advertising claims about energy use or efficiency.
Q: Must manufacturers include the disclosures required by the
Rule on labels of lamp products that are distributed and sold only to others who repackage
the lamps with other products (such as a desk lamp fixture) for resale to consumers or
other users?
A: No. The Rule requires labeling on packaging only for covered
lamp products that are distributed and sold to consumers or other users alone or in
multiple unit packages of lamp products.
Q: Must manufacturers or other sellers of products that
include a lamp product such as desk lamp fixtures include the disclosures
required by the Rule on labels of such products?
A: No. The purpose of the Rule is to provide consumers with
prepurchase information on certain bulbs and tubes so they can compare them and select the
most energy efficient one that meets their needs. Consumers can use the disclosures on
lamp product packages when they select replacement lamp products for desk lamp fixtures or
other products.
Q: Must manufacturers of covered lamps conduct substantiation testing
every time they change components, production procedures or methods?
A: Yes, if the change is likely to affect the lamps light
output, wattage, or life. For example, if a manufacturer starts using a different ballast
in its compact fluorescent lamp, the resulting lamp would be a new product. The
manufacturer would be required to have and rely on a reasonable basis, consisting of
competent and reliable scientific tests, to substantiate the required disclosures for the
new lamp product.
Q: Who should I contact if I suspect non-compliance with the
FTCs lamp labeling requirements, false or misleading claims, or fraudulent activity
regarding the sale of lamp products?
A:
The FTC works for the consumer to
prevent fraudulent, deceptive and unfair business practices in the
marketplace and to provide information to help consumers spot, stop and
avoid them. To file a
complaint or to get free information
on consumer issues, visit
www.ftc.gov or
call toll-free, 1-877-FTC-HELP (1-877-382-4357); TTY: 1-866-653-4261. The
FTC enters Internet, telemarketing, identity theft and other fraud-related
complaints into
Consumer Sentinel, a
secure, online database available to hundreds of civil and criminal law
enforcement agencies in the U.S. and abroad.
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