FTC FACTS for Business

FOR THE CONSUMER 1-877-FTC-HELP

ftc.gov FEDERAL TRADE COMMISSION

Complying with the Appliance 

Labeling Rule: A Guide for Retailers

S ince 1980, manufacturers of certain appliances have been required to attach EnergyGuide labels to their appliances to give consumers important information 

about the energy use of an appliance. The labels must be hung on the inside of the appliance 

or secured to the outside. They are designed to help shoppers choose appliances that use less 

energy and thus cost less to operate and are better for the environment.

The Federal Trade Commission’s Appliance Labeling Rule requires EnergyGuide labels on:

Refrigerators, freezers, dishwashers, clothes washers 

Water heaters, furnaces, boilers

Central air conditioners, room air conditioners, heat pumps 

Pool heaters

Showroom Dealers

If you sell any of these appliances in a showroom, you are not permitted to remove the 

labels, cover them up, or otherwise make them illegible. If a label should become detached 

from an appliance on your showroom floor — a more likely occurrence for hang tags than 

for labels adhered directly to the appliance — it’s a good idea to reattach it. You are required 

to provide this information to your customers.

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Facts for Business 

Online Sellers

If you sell home appliances online, you have to 

provide energy use disclosures pursuant to the 

FTC’s requirements. Consumers who purchase 

appliances through a website or catalog never 

come face-to-face with EnergyGuide labels. 

To ensure that these consumers have access 

to the energy efficiency information on the 

EnergyGuide labels before they buy, the FTC 

requires merchants to post the information on 

their websites, and catalog sellers to print it in 

their catalogs. 

If you sell certain appliances through a website, 

the following questions and answers should help 

clarify your legal obligations.

Q. What energy efficiency information must an 

online seller or a paper catalog seller provide?

A. Dealers who sell covered appliances online 

or through a paper catalog must disclose energy 

information for their products. To do so, they 

have two options:

They can display a copy of the EnergyGuide 

label for each product; or

They can provide the following information 

for each product:

The capacity of the model; 

The estimated annual operating costs, 

and a statement explaining the basis for 

such cost information for refrigerators, 

refrigerator-freezers, freezers, clothes 

washers, dishwashers, room air 

conditioners, and water heaters. The 

required statement varies by product 

and is detailed here [http://ecfr.

gpoaccess.gov/cgi/t/text/text-idx?c=e

cfr&sid=b5cf4c648ccbb8dacc3ea6afd

3520709&rgn=div5&view=text&no

de=16:1.0.1.3.29&idno=16#16:1.0

.1.3.29.0.16.24]; and

The energy efficiency or thermal 

efficiency ratings for pool heaters, 

1.

2.

a.

b.

c.

central air conditioners, heat pumps, 

and furnaces (including boilers).

Q. Must all websites provide this information?

A. Websites must comply with the Appliance 

Labeling Rule’s disclosure requirements if they 

meet the Rule’s definition of a catalog — that is, 

they contain “the terms of sale, retail price, and 

instructions for ordering” the product. 

Q. Where on the website should the disclosure 

information appear?

A. You may put this information next to the 

description of the appliance, or you may use a 

hyperlink to take the reader to another page that 

displays the EnergyGuide label or contains the 

required information. If you use a hyperlink, it 

should be: 

Next to the description of the appliance so 

that the reader will see it. The link should 

be clear and conspicuous, that is, easy to see 

and notice.

Readily identified as a link. Use visual cues 

for the link: make it a different color than the 

surrounding text, underline it, or incorporate 

a small graphic or icon. Using the same text 

style for all hyperlinks throughout your site 

will help the reader identify the link.

Meaningful. It should give the visitor a 

reason to click on it. For example, labeling 

the link “EnergyGuide Information” is 

more likely to bring a consumer to the link 

than a label that says “Legally Required 

Disclosures.” Consider using a yellow-andblack EnergyGuide icon, which you can 

download from the FTC’s website at 

ftc.gov/appliances. 

A direct connection to the energy efficiency 

information. The link should go directly to 

the page providing the information, not to 

an intermediate page that requires the reader 

to click again. In addition, the reader should 

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Facts for Business

not have to scroll down the screen to find the 

applicable information. 

 Q. A manufacturer of covered appliances 

maintains a website with information about its 

products, including model numbers, photos, 

features, technical specifications, dimensions, 

and installation instructions. Is it required to 

post energy efficiency information on the site?

A. A manufacturer is required to include energy 

efficiency information on its website only if 

the site gives prices for the appliances and 

instructions for ordering them. If the site provides 

information about the appliances but doesn’t offer 

them for sale, the FTC’s disclosure requirements 

don’t apply. However, a manufacturer may 

voluntarily place the labels on its websites. This 

helps alert consumers to the energy efficiency of 

its products and also helps retailers who want to 

replace labels that have become detached from 

models in their showrooms. 

Q. A dealer sells appliances through a bricksand-mortar showroom, and maintains a 

website with its address and phone number and 

information about its products. The dealer does 

not sell appliances through the website; indeed, 

it advises shoppers to visit its showroom. Does 

the site have to post the energy efficiency 

disclosures? 

A. If a site does not provide instructions for 

ordering, it is not subject to the disclosure 

requirements. This applies even if the dealer 

accepts orders from consumers who see the 

product information on the website. Nevertheless, 

the dealer may want to provide the energy 

efficiency information as a customer service. 

Q. A dealer sells appliances through a 

showroom and a website, but requires 

consumers who buy online to pick up their 

purchases from the showroom. Is the website 

required to post the disclosures? 

A. Yes. The site is required to post the 

disclosures because it gives instructions for 

ordering appliances. It makes no difference 

whether the purchaser picks up the item at the 

showroom or has it delivered. 

Q. A dealer offers appliances through a 

website. Consumers cannot order online, but 

the site gives consumers a telephone number to 

call to place their order. Is the website required 

to post the disclosures? 

A. Yes. The website is required to post the 

disclosures because it gives customers ordering 

instructions. It doesn’t matter how the customer 

places the order.

Q. A dealer sells appliances through a website 

but doesn’t physically handle the merchandise. 

Once the dealer receives an order, it notifies 

the manufacturer or a local distributor, who 

makes — or arranges for — the delivery. Does 

the website have to post the disclosures?

A. Yes, because the dealer sells the appliances 

through its website, even though it doesn’t stock 

them. 

Q. Company X provides website services to 

an appliance dealer. The company designs the 

dealer’s site, hosts the site on its server, and 

processes credit card orders placed through 

the site. The system routes the ordering 

information to the dealer, who fulfills the order 

and receives the payment via its merchant 

account. Is company X responsible for making 

the website disclosures?

A. No. Company X is involved in online 

appliance sales indirectly. Its services to the 

appliance dealer fall into the category of those 

provided by the dealer’s telecommunications 

provider, landlord, or accountant. In this case, 

the dealer would be responsible for posting the 

required disclosures. 
Facts for Business

1-877-FTC-HELP FOR THE CONSUMER

FEDERAL TRADE COMMISSION ftc.gov

June 2008

Federal Trade Commission

Bureau of Consumer Protection

Division of Consumer and Business Education

Q. A trade association operates a website that 

serves as a locator and host for individual 

appliance dealers’ sites. Based on a template, 

each dealer site has the same layout, but is 

“personalized.” The trade association controls 

what is posted on the sites, and dealers cannot 

alter their sites. Each dealer’s site allows 

customers to order online: When they click 

on a “Shop Online” icon, customers are 

transferred to a page where they select their 

appliance and then click on a “Buy Now” 

icon. The ordering information is transmitted 

directly to the dealer, who fulfills the order. 

Who is responsible for making the energy 

efficiency disclosures?

A. The dealers are responsible for making the 

disclosures. Although the dealers allow the trade 

association to control the site’s content, each 

dealer offers appliances for sale. That makes 

each dealer responsible for disclosing the energy 

efficiency information. 

Q. A portal operates a shopping area. Visitors 

click to a page where they can select a category 

of appliances. After choosing a category, 

they get descriptions of the models offered 

by several dealers, with links to each dealer. 

Visitors can order appliances through the 

portal, which forwards the information to 

the dealer. Who is responsible for posting the 

disclosures?

A. The dealer is responsible for posting the 

disclosures. The dealer is advertising in a catalog 

by virtue of the content maintained on its own 

site.

Q. A website offers information about a 

variety of appliances and recommends specific 

models. Consumers can click on an icon to get 

information about online dealers who sell the 

appliances. They also get information from the 

dealers’ websites, displayed in a frame on the 

page, that they can use to place an order. Who 

is responsible for posting the disclosures?

A. The dealers are responsible for posting 

the disclosures because they are offering the 

appliances on their websites.

For More Information

For more information about the Appliance 

Labeling Rule, visit ftc.gov/appliances. For more 

information about complying with various FTC 

rules and guides, such as those covered by the 

FTC’s Dot Com Disclosures booklet, visit ftc.gov 

and click on Consumer Protection, then Business 

Information. Or, call 1-877-FTC-HELP.

Your Opportunity to Comment

The Small Business and Agriculture Regulatory 

Enforcement Ombudsman and 10 Regional 

Fairness Boards collect comments from small 

business about federal enforcement actions. Each 

year, the Ombudsman evaluates enforcement 

activities and rates each agency’s responsiveness 

to small business. To comment on FTC actions, 

call 1-888-734-3247.