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”), Amendment (R611004)
Concerning Appliance Labeling Amendments, Matter No. R611004 I have read your proposed amendment to rules regarding energy labels on appliances, and on the whole I feel that the proposed changes are both sensible and efficient. However, I wanted to comment on the idea that manufacturers should be required to include QR codes on the label itself. I feel that the requirement of these codes is unnecessary, and a waste of space on the labels that could be used to make helpful information to the consumer easier to read (particularly if the labels are made smaller to accommodate less space inside washing machines). The label is designed to contain information that is useful to someone comparing appliances for purchase, and it would be decidedly unhelpful to have essential information connected to QR codes that so few people use. While a good number of people have smart phones, the use of QR codes is not wide-spread enough to justify this requirement. This may be because smart phones require specific applications in order to "read" the QR code, and these apps may cost extra money. It seems counter-productive to change a rule to make comparison shopping easier on a consumer, and then place the information on the label in such a way that most people cannot access the comparison information. If all of the information required by the FTC and the DOE is on the label (as it should be) then using a QR code seems redundant, as the information it linked to would be of less importance (making it more unlikely that anyone would use it). Generating the QR code itself would not be difficult or time-consuming, as there are QR generators designed for that very purpose, maintaining the website of information would probably not require much more work that the FTC already puts into maintaining its own website. However, even without undue technical demands, and just a small additional cost, the benefits still don't seem to give consumers that much extra help in comparing appliances. Assisting manufacturers who wanted to use QR codes to provide extra information to consumers seems like a good idea, but requiring QR codes invites redundancies, and likely would not be used enough to justify the requirement.