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energy lamps labeling bulbs life
In its NPRM, the Commission proposed a bulb life disclosure stated in years (rounded to the nearest tenth of a year, e.g., 1.1 years), which would be calculated assuming usage of three hours per day.
Comments: Several commenters supported the proposed bulb life disclosure.
In particular, CEE noted that this approach ensures that all manufacturers would calculate life based upon the same assumptions.
The Energy Efficiency Advocates, however, objected to a bulb life disclosure stated in years, recommending a total-hours disclosure.
First, they asserted that predicating a life disclosure on a usage assumption is misleading because such an assumption fails to account for substantial differences in usage among consumers.
Second, they asserted that a disclosure stated in hours is more effective in conveying differences in bulb life than a disclosure in years.
Discussion: Consistent with the NPRM, the final amendments require a bulb life disclosure stated in years rounded to the nearest tenth calculated assuming bulb usage of three hours per day.
For the reasons stated in its NPRM, the Commission finds that this life disclosure will be more useful to consumers than a disclosure expressed in total hours.
In particular, in the study, respondents showed a slight preference for life in years over life in hours and the NRCan research noted that consumers have difficultly relating hours of use to bulb life.
The Energy Efficiency Advocates observation that each consumers bulb usage differs is undoubtedly correct.
However, disclosure of the three-hour per day usage assumption on the Lighting Facts label will allow consumers to compare that assumption to their own expected use. Moreover, by rounding to the nearest tenth of a year, the disclosure will communicate significant differences in bulb life to consumers.
For example, consumers will be able to choose between bulbs with stated lives of 1.7 years and 1.2 years. Finally, relatively small differences in bulb life that may be captured better by a total-hours disclosure likely will become less important to consumers as high efficiency bulbs, some of which can last over a decade, become more prevalent.
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