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APGA Comments on Proposed Energy Labeling Rule (April 18 2024) 

04-18-2024 10:44 AM

On April 18, APGA submitted joint comments with the American Gas Association (AGA) and National Propane Gas Association (NPGA) in response to the Federal Trade Commission’s (FTC) Notice of Proposed Rulemaking on the Energy Labeling Rule. The FTC proposed the Energy Labeling Rule to consider energy labels for several new consumer product categories, including some gas-fired appliances, and changes to label display requirements.
 
Since APGA’s utility members provide the energy for their customers’ gas-fired appliances, it was important to engage in this effort. APGA, along with joint commenters, shared support for the proposed inclusion of the label on the packaging for instantaneous gas heaters and stressed the importance of using a QR code, which would allow the consumer to view additional information about the appliance if they choose. Similarly, the joint commenters shared support of manufacturer proposals of the label on boilers, and specifically endorsed Crown and Burnham’s suggestion of a QR code.
 
Regarding electronic labels, the FTC has made unsubstantiated claims that abandoning physical labels would likely degrade the label’s effectiveness and reduce the program’s benefits for consumers. The FTC also claims that switching to electronic labels would limit access to the label to only a portion of shoppers – those with mobile internet access that take the extra effort to retrieve the information online. APGA, AGA, and NPGA disagree and argue electronic labels would overall be more helpful to the consumer.  The FTC should use technology, like QR codes, to create and promote online resources to better inform purchasers about the full-fuel-cycle, which accounts for emissions and environmental impact of each step in energy delivery, not just the emissions from the individual products.

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APGA AGA NPGA Comment FTC Energy Labeling Rule Improvemen....pdf   243 KB   1 version
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