|Received:||12/23/2009 9:39:15 AM|
|Agency:||Federal Trade Commission|
|Rule:||16 CFR Part 305: Proposed Amendments to the Appliance Labeling Rule That Would Change the Existing Labeling Requirements for Lamp Products (Light Bulbs)|
Comments:Green Seal is an independent non-profit organization dedicated to transforming the marketplace to sustainable products and services. Green Seal does this primarily though an ecolabel program with a standards and certification program. Green Seal has run its effective ecolabel program for 20 years with the aim of helping consumers and purchasers identify environmentally preferable products and services. Green Seal has had an ecolabel program for lighting products since 1992. This program includes a standard that outlines requirements for energy efficiency, long life, product performance, low toxicity, source-reduced packaging, responsible manufacturing, and extended producer responsibility among other health and environmental considerations (e.g. the Green Seal CFL standard, GS-5, can be found at: http://www.greenseal.org/certification/standards/GS-5_cfl.cfm). This program reaches beyond the health and environmental considerations for lighting products covered by Energy Star. As a result, Green Seal’s program has been of interest of purchasers of environmentally preferable products and those purchasers are looking for the recognition that a product meets the Green Seal standard on the product label. Therefore, we request that any changes to lighting product labels allow for the use of the Green Seal certification mark and the statement for the basis of certification on the front panel and the other packaging panels (providing at least what is permitted for the Energy Star logo). Thank you for considering the needs of purchasers and our comments.