Submission Number: 560957-00006
Received: 5/14/2012 8:53:26 AM
Commenter: Lisa Highfill
Organization: IKEA North America Services LLC
Agency: Federal Trade Commission
Initiative: Rule Concerning Disclosures Regarding Energy Consumption and Water Use of Certain Home Appliances and Other Products Required Under the Energy Policy and Conservation Act (“Appliance Labeling Rule”); Amendment (R611004)
Attachments: No Attachments
It is important that manufacturers know which label and what information shall be shown where.
Energy efficiency on product can be divided in 4 different segments
1. Energy efficiency label shown on visible sample in the store including, e.g. annual energy efficiency, annual water usage, annual save and energy class , and for label in the store focus on usage of marks and not text
2. Online selling, same information as information in store but with text instead of marks,
3. Printed media same as online
4. Technical promotion material coming with products same as point 1 but also other technical information.
It would be very good to define that point 1,2,3 shall contain specific information which is good to have during purchase decision and not too much information maybe to analyze 4 main points for each product category.
For e.g. point 4 technical promotion material coming with product itself could contain more detail information.
To make it even more simple is to say that label shown in the store could be used on the internet and in printed media also, and then manufacturer could define by them self if they want to have label printed or if they want to use text.
Quickly going to other parts of the proposed amendments YES we are agree that FTC and DOE regulations shall be harmonized to avoid double reporting