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energy lamps labeling color appearance

In its NPRM, the Commission proposed a color appearance disclosure on the Lighting Facts label consisting of a black and white scale labeled warm on one end and cool on the other.

The scale also included the correlated color temperature of the bulb, measured in Kelvin.

As discussed in the NPRM, this color appearance scale addresses the fact that some bulbs have a warm, yellow appearance, while others have a cooler, white or blueish appearance.

The Commission proposed a scale to describe color appearance because, in the FTC label study, a scale performed better than word descriptors commonly used in bulb marketing such as soft white or daylight. However, the NPRM stated that manufacturers could use such descriptors elsewhere on the package.

In addition, the Commission sought comment on whether the final amendments should require the scale be printed in color. In particular, the Commission sought comment on the costs color printing would impose on small manufacturers. Finally, the Commission asked whether this disclosure should be titled Light Appearance instead of Color Appearance to guard against the impression that the disclosure pertains to colored lights (e.g., red or green).

Comments: No comments objected to requiring a color appearance scale on the Lighting Facts label. Several, however, urged the Commission to use the term light appearance instead of color appearance.

The comments also offered several specific suggestions about the scale.

First, NEMA preferred a scale printed in color, but suggested that manufacturers have the option of printing in black and white. Likewise, CEE suggested that a scale printed in color be optional.

Second, both CEE and NEMA suggested that the highest and lowest Kelvin values appear on the ends of the scale, along with mid-range Kelvin value in the center.

More specifically, NEMA stated that the numbers 2700K, 4100K and 6500K should appear below the scale to clarify the possible range and, in its view, protect against manufacturers trying to enhance the perception of a bulbs color appearance by manipulating the length of the scale.

Third, NEMA suggested that the actual color temperature measured in Kelvin appear in bold on the top of the scale, rather than on the bottom of the scale as proposed. Finally, NEMA suggested that the Commission change the descriptors at the ends of the scale to warm white and cool white.

Discussion: As suggested by the comments, the final amendments use the term Light Appearance instead of color appearance to describe the disclosure on the label.

This change will minimize the possibility that consumers will interpret the disclosure to convey information about colored lights.

While there may be some benefit to a color version of the scale, the final amendments require the black and white version85 for two reasons.

First, a single version ensures consistency, which is essential to building consumer recognition and confidence in the Lighting Facts label. Indeed, if the final amendments permit a scale printed in color, consumers may not understand why one package has a color scale and another has only black and white.

Second, the black and white label requires less package space.

As discussed in section V.B.1, this is an important consideration because of the limited space available for labeling on many bulb packages.

In addition, the final amendments do not require Kelvin measurements at the endpoints and middle of the scale.

Rather, consistent with the NPRM, the final amendments maintain the warm and cool monikers at the ends of the scale, which will correspond to 2600K and 6600K, respectively.

Given the small size of the scale, additional Kelvin numbering could make it difficult for consumers to identify the Kelvin number applicable to the bulb.

Moreover, the final amendments require the light appearance scale to be proportional in size to the width of the label.

Accordingly, the scale will be sufficiently uniform in size to prevent manufacturers from manipulating it in a way that could mislead consumers.

Finally, the amendments do not label the ends of the scale cool white and warm white as suggested by NEMA and GE.

Industry members already use these terms to refer to the specific color temperatures, 3000K and 4100K, respectively.

As noted above, however, the ends of the scale correspond with 2600K and 6600K.

Thus, a label that assigns these terms to the low and high end of the scale would in effect give them new meanings, potentially causing confusion.

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