Rule Concerning Disclosures Regarding Energy Consumption and Water Use of Certain Home Appliances and Other Products Required under the Energy Policy and Conservation Act ("Appliance Labeling Rule")
The Commission specifically asked for comments on the use of comparative model data within the disclosures. I think comparative data would be quite useful. For example, if a seller was merely offering a single television model for sale at a steep mark down, the consumer would not have an opportunity to compare other model's similar energy disclosures. By also disclosing the model's place on a range of other comparably sized models, this will give even the spontaneous consumer the capacity to make a purchasing decision based upon efficiency. I disagree with the ultimate design of the disclosures. While I think the two options presented in the proposed rule are fine themselves, yet I think perhaps in addition to their frontal placement, which will be most beneficial for in-store consumers, there should also be a permanent sticker affixed to the back of the product. Leaving the information affixed to the product will allow consumers to base considerations of future purchases of televisions based on what would be an estimate of their current energy consumption and will aid in determining whether a consumer might be interested in replacing an existing television. This permanent sticker should also include an additional emphasis noting the energy prices on which the estimates were based to avoid potential consumer confusion later on. The costs of producing these stickers may be slightly more and its ultimate benefit maybe marginal. However, it nonetheless is at least worthy of passing consideration. The Commission specifically asked for comments on including the disclosures on other electronic devices. I do not think it is unreasonable for these types of disclosures to be applied to many types of devices. Certainly, there is a point where the relative energy use does not equate to the cost of testing and making the disclosures. Nevertheless, I think it is not unreasonable to require energy disclosures for all of the other entertainment products mentioned within the Notice.