TV Makers Urge Electronic Labeling in Lieu of Physical EnergyGuide Labels

TV makers sought an electronic labeling alternative to physical labeling, in comments on an FTC rulemaking to extend EnergyGuide Labeling requirements to sets and other consumer electronics. They also opposed a proposal to require energy use information on packaging materials for TVs, saying it would not benefit consumers but add costs to manufacturers.

Suggesting the use of an electronic label that will show directly on the TV screen, Sony said displaying energy use information in a “timed loop” in the set’s retail mode setting would provide “customers easy access to the required energy guide data while presenting the least burden for manufacturers and retailers.” Electronic labels also would help avoid “mislabeling as would happen with a physical label,” the company said. If the commission settles for a physical label, it should require it only at the retail location and allow it to be affixed to a “visible location on the television other than the viewing surface,” Sony said.

Panasonic suggested that the commission allow energy use information to be “prominently displayed” in an on-screen setup menu. The menu could be activated either by the retailer while preparing a set for floor display or by a consumer testing the TV, it said. “Electronic display of the information can be cycled on a regular basis, ensuring consumers access to energy usage information while maintaining use of the demonstration video content used in promotion of the TV’s picture performance.” Electronic labeling should be option, said Sharp Labs, calling for an “explicit exemption” from labeling requirements for TVs that run on batteries.

Mitsubishi said it agrees with the CE Retailers Coalition that labeling should be the manufacturers’ responsibility and that “any requirement on retailers to attempt to match labels with products will not yield perfect compliance due to the retail sales environment.” Labeling on boxes in addition to sets is unwarranted, the company said. Except for online purchases, consumers hardly buy TVs without examining an unboxed working set, it said. Most boxes for TVs are printed “at least six months in advance, while the energy consumption data is typically available only a few weeks before shipping,” said Sony. “Therefore labeling on the box may not be 100 percent accurate at the time of printing, violating Energy Star rules.” Physical labeling on each TV sold or on the box is “very labor intensive and costly,” it said. “Ultimately, this would nullify any environmental benefit the commission is trying to achieve."

The FTC should publish its final TV labeling rule by this summer if it intends to have new 2011 models carry EnergyGuide labels, said Panasonic. Mitsubishi wanted the effective date to be set in early summer and the “effective date should not be less than six months later than the final rule publication in order to allow for label design and production."

Since computers are customized by consumers with different processors, memories and drives, it would be “nearly impossible to develop an estimated annual energy use,” said Sony. “For computers, even identical models can produce broad differences in energy consumption based upon usage and software.” So before requiring labeling for computers, the commission should “carefully consider the relative benefits to consumers and the environment against the potential costs,” the company said. Sony also believes that energy labels for video products will not help consumers with purchasing decisions, it said: “Unlike set-top boxes which are constantly drawing power, consumers tend to use video products sporadically."

The National Cable and Telecommunications Association said the commission was correct in concluding that labeling requirements are not warranted for cable or satellite set-top boxes for now. Even if consumers took into account the energy use of set-tops supplied by service providers as part of their decision to subscribe to cable or satellite service, “that would not appear to satisfy the statutory requirement that any FTC-mandated labeling must be likely to assist consumers in making purchasing decisions about the equipment,” the group said. “Beyond these statutory considerations, the marketplace reality is that consumers comparison-shop” among service providers based on service offering and not equipment, it said. The group urged the commission to conclude that further consideration of labeling requirements for set-tops is not warranted.