CEA Urges Flexibility in FTC’s Proposed EnergyGuide TV Labeling Rules

The FTC must give CE makers and retailers flexibility to choose the “appropriate attachment mechanism, location and color scheme” of energy use disclosure labels as it devises labeling requirements for TVs, CEA said in comments at the agency. The FTC started a rulemaking on EnergyGuide labels for TVs and other CE products so consumers will have more information on their energy use. “The goal must be to maximize consumer accessibility to the label, while recognizing the varied ways TVs are displayed for sale,” CEA said.

The commission had proposed either a small rectangular adhesive label on the “bezel,” the border or frame surrounding a TV, or a triangular cling label on the bottom right hand corner of the screen. Some retailers and manufacturers have “strong aversion” to cling label affixed on screen, the CEA said. And some TVs don’t have a border or frame, it said. At the 2010 CES, several TV makers displayed sets without borders or frames, a model they intend to introduce in the market this year, the group said. “It is too early to know if this innovative design will start a trend toward TV screens without bezels, but we note the importance of having energy disclosure labeling rules that can accommodate future innovation in product design."

The commission should allow using both labeling options it has proposed because multiple options will be “future proof,” CEA said. The commission also must weigh a “hand tag” option, it said. “The commission claims that hang tags could become easily dislodged, but evidence for this conclusion is not provided.” Electronic labeling must also be considered, although the concept needs “considerable further exploration” to ensure that sales associates and consumers can easily get energy use information at retail, CEA said. The FTC must act quickly to probe the use of electronic labeling as an option, it said.

CEA backs the commission’s proposal to require that energy-use disclosures contain annual energy costs based on electricity rates of 11 cents per kilowatt hour and usage rate of five hours a day in on mode and 19 hours a day in standby mode, it said. The group suggested some changes to the FTC’s requirement for comparative energy use information based on screen size that it said would “more accurately” compare TVs to similar models in the marketplace.

The FTC shouldn’t require energy use labels for portable TVs and those used in automobiles that operate on battery power, including rechargeable batteries, CEA said. While CEA has no position on the six months “lead time” that the FTC is proposing for complying with energy disclosure rules, the group wants the commission to “set an effective date that provides both sufficient lead time and take takes effect in early summer, the traditional model change period,” it said.