Submission Number: 549189-00009
Received: 7/13/2010 2:27:38 PM
Organization: Project Light
Agency: Federal Trade Commission
Initiative: 16 CFR Part 305: Final Amendments to the Appliance Labeling Rule That Require Changes to the Existing Labeling Requirements for Lamp Products (Light Bulbs)
Attachments: No Attachments
I believe these new labels are missing some information and I recommend you add some information such as the follows.
1. ) Some sort of efficiency rating such as lumens per watt such as for the 60W Bulb it would be 13.67 L/w and for the 13W it is 66.92
2.) I still believe most people think of light output by incandescent equivalent and it might be good to keep some sort of data on the label saying what it is equivalent to a standard light bulb.
3.) For the mercury it might be a good idea to list how much mercury is in the bulb. As a way for manufacturers to be pushed to lower mercury content.
4.) This label is very basic which has its advantages but it might be a good idea to look at and adopt something more similar to the EU Energy Label.
5.) Maybe made the labels a different color (such as green) if they are within a certain about of lumens per watt.
6.) Change Life to Estimated life because certain bulb types turning them off and on multiple times a day for a few minutes at a time could lower there life.