16 CFR Part 305; Agency Information Collection Activities; Comment Request; Energy Labeling Rule: FTC Project No. R611004 #00008

Submission Number:
00008
Commenter:
Alex Boesenberg
Organization:
National Electrical Manufacturers Association (NEMA)
State:
Virginia
Initiative Name:
16 CFR Part 305; Agency Information Collection Activities; Comment Request; Energy Labeling Rule: FTC Project No. R611004
December 04, 2017 ONLINE VIA: https://ftcpublic.commentworks.com/ftc/labelranges/ Mr. Hampton Newsome Division of Enforcement Bureau of Consumer Protection Federal Trade Commission Room CC--9528, 600 Pennsylvania Avenue NW. Washington, DC 20580 Regulatory Information Number: 3084--AB15 Dear Mr. Newsome, As the leading trade association representing the manufacturers of electrical and medical imaging equipment, the National Electrical Manufacturers Association (NEMA) provides the attached comments on the Department of Energy Request for Information regarding the FTCs Energy Labeling Rule. These comments are submitted on behalf of NEMA Light Source Section Member companies. NEMA, founded in 1926 and headquartered in Arlington, Virginia, represents nearly 350 manufacturers of electrical equipment and medical imaging technologies. Our combined industries account for more than 360,000 American jobs and more than 7,000 facilities across the United States. Domestic production exceeds $106 billion per year and exports top $36 billion. Regarding the proposed changes to 16 CFR clause 305.10, with respect to their mention of labeling requirements for lamps, NEMA agrees with this proposal. The remaining portions of the NOPR are outside of the scope of NEMA products, and as such we refrain from comment on those. If you have any questions on these comments, please contact Alex Boesenberg of NEMA at 703-841-3268 or alex.boesenberg@nema.org. Sincerely, Kyle Pitsor Vice President, Government Relations National Electrical Manufacturers Association National Electrical Manufacturers Association 1300 North 17th Street, Suite 900 - Rosslyn, VA 22209