Consumer Electronics Labeling #540779-00001

Submission Number:
Lonny Paul
Initiative Name:
Consumer Electronics Labeling
The FTC's goal of providing the consumer energy consumption data is admirable, however some areas of the proposal will provide functional problems, as they have before. Requiring retailers to provide this energy information in correlation with the sale of items covered by this regulation, without a central repository of data for all models by the FTC to provide retailers with a central resource for consistent data on applicable products. Without this centralized datasource, retailers will be unable to keep up with the myriad of models and products which go on and off salesfloors and websites each day. I believe that there can be great cost differentials between models and types of televisions and other products, such as desktop computers, laptops and even home theater equipment. Any device which exceeds a certain level of energy on an annual basis should be considered for inclusion on under this program. Finding a way to better inform consumers how a plasma TVs power consumption is far different from that of an LCD TV is a whole other ballgame - consumer education must be tightly tied into this program, providing information with which consumers can make informed decisions. The FTC should continue to maximize the efficiency of using the EPAs existing guidelines and procedures as adopted for this program - failure to do so could only shed a light of oversized government and disagreeing divisions. Sharing data and standards goes a longway to better inter-agency efficiency. Utilizing independant laboratories is not a good idea, as we see how that worked for the cigarette industry in the 50s and 60s. Retailers should be encouraged to provide the information to consumers, however not be required. Participating retailers should only use the information when it is the same as provided by the MFG to the FTC for compliance under these guidelines and ensure consistency of information across all possible outlets. Comparative information SHOULD be provided for the consumer across the product category as well as any sub-category (ie TVs / Plasma TVs / Size). Consumers should be aware of the entire category to determine if they have made a good selection overall. Simply using screen size is not valid as a 72" DLP vs. Plasma vs LCD are complete differently beasts. Manufacturers should be required to report on a consistent data set, perhaps including: Mfg Model Mfg Part # Product Name Category: (ie Television / Microwave / Air Conditioner) Sub-Category: (ie: Plasma / LCD / DLP / Tube TV / OLED TV) Unit Size: (ie 27, 30, 32, 37, 40, 42, 47, 50, 52, 57, 58, 60, etc.) Power consumption per viewing hour:(actively powered on) Power consumption during non-viewing hours: (idle, plugged in) All relevant information should be available from the FTC in a centralized location. Thank you for reading and taking my considerations into account.