Recently, the Commission voted to accept an interpretive amendment to the lamp labeling requirements of the Appliance Labeling Rule that would allow light bulb manufacturers and private labelers to make required disclosures only on bulk shipping cartons, where light bulbs are not individually packaged and labeled for retail sale. The light bulbs themselves would only be etched with information on wattage and would exclude information required for energy conservation, such as lumens and hours.
I dissented from this vote because I believe that this proposal compromises the amount and quality of information available to consumers, without a showing of some other significant benefit to consumers. In this case, the primary beneficiaries of the alternative packaging appear to be the businesses that save themselves the costs of individual packaging and labeling. While I understand that consumers might be able to buy their bulk light bulbs at lower cost, there is no evidence that cost savings would actually be passed on to consumers. Moreover, the marginal savings that might be given to consumers are not, in my view, sufficient to warrant a significant change in how consumers receive Congressionally-mandated information or to sacrifice the benefits of current packaging and labeling to consumers who buy and keep light bulbs for future use.