16 CFR Part 460: Labeling and Advertising Of Home Insulation: Trade Regulation Rule; Comment Request; R-value Rule (Project No. R811001) #00007

Submission Number:
00007
Commenter:
Anonymous
Organization:
Initiative Name:
16 CFR Part 460: Labeling and Advertising Of Home Insulation: Trade Regulation Rule; Comment Request; R-value Rule (Project No. R811001)
The Federal Trade Commission's Trade Regulation Rule Concerning the Labeling and Advertising of Home Insulation - also known as the R-value rule - is an asset to the marketplace for housing-related products and the Commission's purposed changes would further improve the rule's effectiveness. The R-value rule offers an important protection for consumers. It ensures that people buying insulation have fair, accurate, and consistent standards for determining the quality of home insulation. In particular, an insulation product's "R-value" amounts to a standardized determination regarding a product's relative ability to limit heat flow from a person's home. As a result, the rule rates an insulation product's ability to reduce energy costs for consumers. The R-value rule's standards consequently empower individual consumers operating within the marketplace and give them meaningful leverage against the exploitative practices of large companies. More specifically, the rule provides consumers with the information necessary to plan for energy costs associated with heating their homes. Thanks to this rule, consumers can analyze the relative cost of buying better insolation compared to the benefit of having lower energy bills. Rather than mandating that consumers purchase a certain kind of insolation, the rule allows them to make that choice on their own. Consequently, it cuts out the middleman for providing information on the quality of types of insolation by placing the onus on large manufacturers for determining the relative quality of their products. Instead of needing to buy possibly unreliable information from third parties, the R-value rule provides consumers with a straightforward and efficient system for making this determination. Consequently, the rule also promotes better practices pertaining to environmental protection. It helps prevent consumers from unknowingly buying faulty or inadequate insolation-related products for their homes. This heightened knowledge base helps consumers make smart environmental choices in an economically advantageous manner. Therefore, these better decisions improve the efficiency of America's system for power production and distribution in the aggregate. Moreover, the Commission's proposals would help strengthen the rule's ability to provide these positive outcomes for consumers and society at large. In particular, the purposed provisions requiring sellers to use the rule's testing requirements to verify any R-value claims for non-insulation products, clarifying that online retailers are required to provide labels and fact sheets, and eliminating reference to an outdated aging specifications would all help arm consumers with better and more accessible information regarding heating insolation. Therefore, the purposed changes should be adopted, because they would make an already good rule even better.