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energy label lumens per watt
In its NPRM, the Commission did not propose requiring lumens per watt on the Lighting Facts label because, in its study, respondents viewing lumens per watt information were more likely to provide incorrect answers to most energy use and efficiency questions than respondents viewing other descriptors.
In addition, lumens per watt information could lead consumers to choose brighter bulbs than needed.
Lumens per watt, however, is a common efficiency metric used in the lighting industry and serves as the yardstick for DOE efficiency standards and performance criteria in the ENERGY STAR program. It also appears on the label developed by DOE for its LED program.
Therefore, the Commission sought comment on whether to allow or require a lumens per watt disclosure on the Lighting Facts label.
Comments: Most comments recommended a voluntary lumens per watt disclosure on the Lighting Facts label.
For example, CEE agreed that the FTC should not require lumens per watt, but believed a voluntary disclosure should be permitted because lumens per watt is the standard metric for efficiency within the lighting industry. The Energy Efficiency Advocates agreed, predicting that consumers will have greater recognition of and interest in lumens per watt in the future, especially after implementation of EISAs public education programs.
OSRAM also favored a voluntary lumens per watt disclosure, asserting that this will eventually become the preeminent method for communicating energy efficiency for general service lamps. OSRAM explained that, like miles per gallon for fuel economy, lumens per watt allows consumers to compare efficiency across product types and brands.
Discussion: Despite these comments, the final amendments do not allow lumens per watt on the Lighting Facts label.
The FTC designed its Lighting Facts label for typical consumers, and, as demonstrated by the FTCs research, the inclusion of lumens per watt information likely will not assist these consumers. As detailed in the NPRM, lumens per watt performed poorly in helping respondents answer energy use and efficiency questions.
Moreover, because consumers are not yet familiar with the basic concept of lumens, the more complex lumens per watt disclosure likely would be ignored or cause confusion, hindering consumers transition to using lumens.
Additionally, as discussed above, lumens per watt could lead consumers to choose bulbs that are brighter than needed.
Nevertheless, nothing in the Rule prohibits manufacturers from providing lumens per watt information elsewhere on their packaging or in other marketing materials.
In addition, once consumers become more familiar with the concept of lumens, the Commission can revisit whether to require, or allow, lumens per watt on the label.
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