| Comment Number: | 519870-00012 |
| Received: | 01/13/2006 12:20:20 PM |
| Organization: | Enivronmental Protection Agency |
| Commenter: | Sheila Frace |
| State: | DC |
| Agency: | Federal Trade Commission |
| Rule: | Energy Policy and Conservation Act - Appliance Labeling Rule |
| Docket ID: | To Be Added |
| Attachment: | 519870-00012.pdf Download Adobe Reader |
Comments:
Mr. Hampton Newsome Federal Trade Commission/ Office of the Secretary Room H-135 (Annex O) 600 Pennsylvania Avenue, NW Washington, DC 20580 RE: Energy Labeling, Project No. R511994 Dear Mr. Newsome: The United States Environmental Protection Agency (EPA) is pleased to provide comments on ways to improve the current Federal Trade Commission (FTC) product labels with respect to water-use information. EPA supports the Federal Water Pollution Control Act and the Clean Water Act by promoting effective and responsible water use, treatment, disposal and management. One of our main focuses in the upcoming years will be to promote efficient water use through education and product review. Our research shows that consumers are interested in environmental information about the products they choose and feel more information is helpful to them in making those choices. We have also found that the Energy Guide is a valued and trusted resource for this information. The FTC currently requires manufacturers of showerheads, toilets, faucets and urinals to display water-use information on the packaging, and we agree that this can be useful to consumers in making product choices. Our first concern is that water-use information may be hard to find on products and packages. A quick survey in a local retailer revealed that on many plumbing products it is obscured either through extremely small type fonts or lost amongst other information. We even noted some cases with no water-use information at all. We therefore recommend three changes to the labeling guidelines for plumbing products that would better enable consumers to compare product information: 1. Prominently place the information so that it is easy to find, such as on the front of the package or product label; 2. Require a larger minimum font size, such as 16 point or greater; and 3. Identify the range of water use for similar products available in the market place. Secondly, the Energy Star program has revised its specification for residential clothes washers, which will become effective in January 2007. The new specification will require Energy Star machines to have a water factor of 8 gallons/cycle/ft3 or less. Clothes washers are a major residential water user and account for over 20% of indoor water use. Therefore we recommend including the water factor on a revised Energy Guide label so that consumers can easily compare product water-use information. We believe that this change has the potential to greatly enhance EPA’s water efficiency efforts. Finally, EPA is in the process of developing a water-efficient product market enhancement program. The program aims to develop performance and water-use specifications for a number of water-using products, including all those currently labeled under the FTC’s guidelines. While we are not considering a specific label at this time, having water-use information clearly available on the product would greatly assist our education and outreach efforts. As our program moves forward, we would like to ensure our efforts are coordinated and complementary where appropriate. If you would like further information on our water efficiency program, please contact Benjamin J. Hamm at 202-564-0648. Sincerely, Sheila Frace Director Municipal Support Division