|Received:||12/22/2009 8:29:31 PM|
|Organization:||ECHIP (East China Hi-tech Industrialization Park)|
|State:||Outside the United States|
|Agency:||Federal Trade Commission|
|Rule:||16 CFR Part 305: Proposed Amendments to the Appliance Labeling Rule That Would Change the Existing Labeling Requirements for Lamp Products (Light Bulbs)|
Comments:ECHIP (East China Hi-tech Industrialization Park) is a government organization for developing photo-electronic related technology like solar photovoltaics, semiconductor lighting, and flat panel display technologies in East China. For detail information, please visit www.e-chip.org.cn. I am the vice CTO (Chief Technical Officer) of ECHIP. ECHIP concerns the environmental pollution issues very much. The labeling of new generation environmental friendly lighting products will have great impact on Chinese lightning industry and our environment as well. We are very happy to see that the USA is proposing and will enforce the new regulation for low Hg containing lamps. It is our comments that: 1. The maximum amount of Hg contained in a fluorescent lamp product must be clearly specified. 2. The minimum efficiency of LM/W must be specified clearly as well as the overall minimum LM (Lumen) of the lamp. 3. If the lamp is associated with a electronic ballast, the above said specification for the efficiency LM/W and overall LM must be measured with the associated ballast, not for the lamp tube only. 4. The minimum life span for light lumen output drop 50% from the initial lumen output must be specified clearly. And the product quality assurance system must make sure the product in the market will be strictly conforming with the above specification labeling. This is to ensure that new replacement energy saving lamps for the old incandescent light bulb will be efficient and effective and environment friendly.