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FTC - Complying With the Appliance Labeling Rule: Labeling Light Bulbs

10/1/2007

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FTC LogoThis information is provided under a cooperative agreement between the Better Business Bureau and the U. S. Federal Trade Commission (FTC), which has prepared this information.

Facts For Business
Complying With the Appliance Labeling Rule: Labeling Light Bulbs
Introduction What are the Requirements Who Must Comply What Products are Covered How to Comply Requirements for All Cartons of Covered Lamp Products Shipped Within or Imported into the U.S. Requirements for Promotional Materials Displayed or Distributed at the Point of Sale Requirements for Catalogs Testing and Sampling Requirements Record Keeping Requirements Submission of Test Data Records Supplying Specimens for Testing By a Laboratory Designated by the FTC Questions and Answers 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.

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.

Who Must Comply
The Rule applies to those who:

manufacture, private label, import, distribute, or sell covered lamp products to retail consumersprepare printed material about covered lamp products for display or distribution at the point of retail saledisplay 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.

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 moreU-shaped lamps 22 to 25 inches long with a rated wattage of 28 or moreEight 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.

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 package’s 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 lamp’s 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 lamp’s design voltage. If the lamp’s 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 lamp’s 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 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 manufacturer’s 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.

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.

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.

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 andThe 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.

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."

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.

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.

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.

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 it’s the manufacturer’s 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 lamp’s 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 lamp’s design voltage. However, manufacturers and private labelers may include the additional disclosures of the lamp’s 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 lamp’s 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 FTC’s lamp labeling requirements, false or misleading claims, or fraudulent activity regarding the sale of lamp products?

A:

For More Information
The FTC works for the consumer to prevent fraudulent, deceptive, and unfair practices in the marketplace and to provide information to businesses to help them comply with the law. 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.

Your Opportunity to Comment
The National Small Business Ombudsman and 10 Regional Fairness Boards collect comments from small businesses about federal compliance and enforcement activities. Each year, the Ombudsman evaluates the conduct of these activities and rates each agency's responsiveness to small businesses. Small businesses can comment to the Ombudsman without fear of reprisal. To comment, call toll-free 1-888-REGFAIR (1-888-734-3247) or go to www.sba.gov/ombudsman.

This information is provided under a cooperative agreement between the Better Business Bureau and the U. S. Federal Trade Commission (FTC), which has prepared this information. The FTC works to prevent fraudulent, deceptive and unfair business practices in the marketplace and to provide information to help consumers spot, stop, and avoid these practices. To learn more about the FTC and its services, visit www.ftc.gov or call toll-free, 1-877-FTC-HELP (1-877-382-4357); TTY: 1-866-653-4261. 
 

 

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