In comments submitted late last month, APGA told the Federal Trade Commission (FTC) that it should update its yellow energy labels, meant to help consumers in their purchasing decisions, to reflect the full fuel cycle (FFC) information of a given appliance. APGA jointly submitted the comments in coordination with the National Propane Gas Association (NPGA) and American Gas Association (AGA) in response to an advance notice of proposed rulemaking (ANOPR) from the FTC, which asked the public for any potential updates it should make to the existing energy label.
FTC’s yellow EnergyGuide labels are required to be displayed on many household appliances for sale in stores. End-users of gas-fired appliances utilize EnergyGuide labels to assess the energy efficiencies of appliances and energy sources. Unfortunately, current regulations only require that country-wide averages for site energy use and cost must be included on the label. Instead, APGA and co-commenters argue that the labels would be more accurate and helpful if they directed consumers to a site that provided FFC data for more localized information on cost, energy use and emissions.
As support for the recommendation, APGA and the others reminder the Commission 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. FTC issued a rulemaking in a 2013 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.”
APGA also submitted similar comments in a more narrow FTC rulemaking last year. The recent ANOPR was much more broad and allowed for APGA to submit more comprehensive comments. 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.
A copy of the comment letter is available
here.
For questions on this article, please contact Stuart Saulters of APGA staff by phone at 202-802-0493 or by email at
ssaulters@apga.org.