3E Lighting Inc.
Outside the United States
16 CFR Part 305: Appliance Labeling Rule, Proposed Rule to Expand Coverage of the Lighting Facts Label, FTC Project No. P084206
SUPPLEMENTARY INFORMATION ‘‘Notice of Proposed Rulemaking on Expanded Bulb Coverage for the Lighting Facts Label (16 CFR part 305) (Project No.P084206)’’ My comments to FTC are: The CFL lamps must be printed that value of mercury contains such as Hg X.X mg on package and product in a small place on FTC Lighting Facts Label (please re-design it) and on lamp tube or on somewhere of integral CFL. Other lamp source had toxic and hazardous materials shall done the same. According to Euro Article 5(1)(a) of Directive 2002/95/EC, a maximum concentration value of 0,1 % by weight in homogeneous materials for lead, mercury, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated biphenyl ethers (PBDE) and of 0,01 % by weight in homogeneous materials for cadmium shall be tolerated.’ Currently the CFL manufactories in China have two ways to meets RoHS required that MUV 0,1 % by weight limitation in homogeneous materials for lead, & mercury and 4 others. First step make 15 samples for each lamp depend how many wattages manufacturer needs send to SGS Lab Inc for toxic and homogeneous materials tested, They knew that SGS tester engineer does not operated these lamps intended lead, & mercury will a little lower or just met 0.1 % by weight of RoHS required toxic limitation. Those send for SGS tested CFL lamps Hg intended will be as below: T3 13W