Earlier this week, APGA, the American Gas Association (AGA), and the National Propane Gas Association (NPGA) commented to the Federal Trade Commission (FTC) on the need to update the EnergyGuide labels, which are required for a variety of appliances, including refrigerators, freezers, dishwashers, water heaters, furnaces, and pool heaters. The input was in response to a notice of proposed rulemaking (NPRM). The main recommendation from the trade associations was that the FTC should include Full Fuel Cycle (FFC) information among the revisions to the EnergyGuide labels. End-users of propane and natural gas as well as manufacturers, distributors, and retail operations that install appliances utilize EnergyGuide labels to assess the energy efficiencies of appliances and energy sources.
As support for the recommendation, APGA and the others provided that the Energy Policy Act of 2005 (EPACT) requires the FTC to consider “the effectiveness of the consumer products labeling program in assisting consumers in making purchasing decisions and improving energy efficiency.” EPACT directs the FTC to consider “changes to the labeling rules that would improve the effectiveness of consumer product labels.” Over the last decade, the FTC has considered incorporation of FFC information in EnergyGuide labels. The latest activity by the FTC was in a 2013 rulemaking in which the FTC stated that it would continue to work with the Department of Energy (DOE) “to consider this issue as part of the regulatory review.” Incorporation of FFC information into EnergyGuide labels during this rulemaking process would finalize the FTC’s commitment to provide consumers with complete information on energy efficiency of appliances from source-to-site.
To see the entire comment letter,
click here.
For questions on this article, please contact Stuart Saulters of APGA staff by phone at 202-544-1334 or by email at
ssaulters@apga.org.