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energy label lamp wattage
In its NPRM, the Commission proposed requiring wattage on the Lighting Facts label and not on the front of the package. The Commission explained that, presently, consumers use wattage as a proxy for brightness.
Therefore, a mandatory wattage disclosure on the package front could impede consumers transition to lumens as the primary brightness indicator for high efficiency bulbs.
At the same time, as noted in the NPRM, the proposed amendments retained a less prominent wattage disclosure on the Lighting Facts label because precise wattage information may be important to consumers seeking to ensure a bulb does not exceed the maximum wattage allowable for a particular fixture.
Comments: Gannon argued that by making the wattage disclosure less prominent, the Commission will make it difficult for consumers to determine whether a bulb meets the wattage ratings of certain lamp fixtures. Specifically, Gannon recommended that wattage appear as the second disclosure on the Lighting Facts label immediately after lumens.
The Energy Efficiency Advocates argued that the Commission should change the proposed energy used descriptor for wattage to a more technically correct term such as power or electricity used. They argued that the proposed wording perpetuates consumer confusion about the difference between power and energy.
In contrast, both NEMA and GE found energy used acceptable.
Discussion: The final amendments continue to require wattage as the fifth disclosure on the Lighting Facts label.
As discussed in the NPRM, many consumers use wattage as a proxy for brightness.
To the extent the ranking of a descriptor on the Lighting Facts label makes it more likely that consumers will view that descriptor, the other descriptors listed before watts on the label brightness, energy cost, life, and color appearance are more important attributes for consumers to consider when choosing high efficiency bulbs. In any event, there is no evidence that the hierarchy of descriptors on the Lighting Facts label materially impacts consumers perception of one descriptor over another.
The final amendments continue to require the term energy used to describe watts on the label.
While the term power is technically accurate, energy used has appeared on the label for nearly two decades without any apparent problems.
In addition, some consumers might incorrectly interpret the term power to relate to the strength of light output.
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