ftc lamp labeling requirements
DESCRIPTION
Phase-In of Energy-Efficient Lighting BriefingHampton Newsom, Attorney, Division of Enforcement, Federal Trade Commission October 20, 2010. An informative briefing on efforts planned and underway by a variety of key stakeholders to ensure the successful phase-in of efficient lighting.Hosted by the Alliance to Save Energy and the National Electrical Manufacturers Association.TRANSCRIPT
FTC Lamp Labeling Requirements
Hampton NewsomeU.S. Federal Trade Commission
FTC protects consumers by ... ... combating telemarketing fraud, Internet
scams, deceptive advertising, and other harmful business practices.
Disclaimer –The views expressed in this presentation are my own and do not necessarily reflect those of the Commission, or of any individual Commissioner
Lamp Labeling
FTC’s Labeling Rules(16 CFR Part 305)
Current (Old) Lamp Disclosures
New Lamp Labels (2011)
New Lamp Labels (2011)
CFLs
Covered Lamp Products
FTC “Lighting Facts” - Medium Base General Service Incandescent, Compact Fluorescent, and LED Lamps
Substantiation
Must use existing DOE test procedures where applicable
If no DOE test procedure exists, must have competent and reliable scientific evidence
Rule also identifies “safe harbor” tests (IES procedures)
16 CFR 305.5
Additional Requirements
Lumens (& mercury) on bulb itself Rules for cost and life-related
advertising claims on the package Disclosures on websites
Compliance and Consumer Ed
Downloadable artwork for the labels at the FTC website: www.ftc.gov/energy
FTC staff is working on consumer education activities
Enforcement
Civil penalties ($110 per violation) (16 CFR 1.98 & 305.4)
Injunctive relief (42 U.S.C. 6304) Citizen suit provision (42 U.S.C. 6305) Recent lawsuit (FTC v Lights of
America, Inc.) – alleges deceptive light output and life claims for LED products
Green Claims
Proposed amendments to Green Guides announced October 6, 2010
Broad green claims nearly impossible to substantiate
Qualify certification claims