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 Facts For Business  Email
 **Complying With the Appliance Labeling Rule: Labeling Light Bulbs** Introduction
             What are the Requirements
             Who Must Comply
             What Products are Covered
             How to Comply
             Requirements for All Cartons of Covered Lamp Products Shipped Within or Imported into the U.S.
             Requirements for Promotional Materials Displayed or Distributed at the Point of Sale
             Requirements for Catalogs
             Testing and Sampling Requirements
             Record Keeping Requirements
             Submission of Test Data Records
             Supplying Specimens for Testing By a Laboratory Designated by the FTC
             Questions and Answers Introduction This booklet summarizes the lamp
             labeling requirements of the Appliance Labeling Rule (the
             Rule) to help you comply with the package labeling,
             catalog, and point-of-sale disclosure rules for general
             service incandescent lamps (reflector and non-reflector),
             medium screw base compact fluorescent lamps, and general
             service fluorescent lamps. The booklet answers
             commonly-asked questions and includes the lamp labeling
             requirements. The explanations in this publication
             refer to the cited sections of the Rule. You will find
             additional information in the statement of basis and
             purpose for the Rule, 59 Fed. Reg. 34014 (1994). The lamp
             labeling requirements were mandated by the Energy Policy
             Act of 1992 amendments to the Energy Policy and
             Conservation Act of 1975, 42 U.S.C. 6201, 6291-6309. Although the Rule became effective May
             15, 1995, the FTC delayed enforcement for incandescent
             lamps until December 1, 1995. [back to top] What
             Are the Requirements The Rule requires that packaging for
             three types of lamps — general service incandescent
             (including both reflector and regular light bulbs),
             medium screw base compact fluorescent, and general
             service fluorescent — include specific information
             to help consumers buy the most energy-efficient lamps for
             their needs. The Rule also requires the manufacturers,
             distributors, and retailers of these products to include
             certain disclosures in catalogs consumers use to order
             the products, and in certain point-of-sale written
             materials. [back to top] Who
             Must Comply The Rule applies to those who: manufacture, private label,
               import, distribute, or sell covered lamp products
               to retail consumersprepare printed material about
               covered lamp products for display or distribution
               at the point of retail saledisplay or distribute printed
               material about covered lamp products at the point
               of retail sale
             promote covered lamp products in a
               catalog from which retail users (consumers) can
               order them. [back to top] What
             Products are Covered Section 305.3(k)-(m) of the Rule refers
             to the following covered products or covered
               lamp products. Incandescent Lamps For purposes of the Rule, the term general
                   service incandescent lamps includes: (1) nonreflector
                 incandescent lamps (including tungsten-halogen lamps)
                 that have a rated wattage of 30 or higher, an E26 medium
                 screw base, and a rated voltage or voltage range at least
                 partially within 115 and 130 volts; and (2) reflector
                 lamps (other than colored lamps or those designed for
                 rough or vibration service applications) that contain an
                 inner reflective coating on the outer bulb to direct the
                 light, an R, PAR, or similar bulb shape (excluding ER or
                 BR), a rated wattage of 40 or higher, an E26 medium screw
                 base, a rated voltage or voltage range at least partially
                 within 115 and 130 volts, and a diameter exceeding 2.75
                 inches. See section 305.3(m)(2)-(3) of the Rule
                   for the specialty-type incandescent lamps that are
                  excluded from the Rule. Medium Screw Base
                     Compact Fluorescent Lamps   Straight-shaped lamps with a rated
               wattage of 28 or moreU-shaped lamps 22 to 25 inches
               long with a rated wattage of 28 or moreEight foot long rapid start lamps
               of 0.800 nominal amperes
             Eight foot instant start lamps
               with a rated wattage of 52 or more See section 305.3(k)(2)-(3) of the Rule
             for the kinds of fluorescent lamps that are excluded from
             the Rule. [back to top] How
             to Comply Required Labeling for
             Covered Products Section 305.11(e) of the Rule
               defines the labeling requirements. All disclosures must
               be made clearly and conspicuously, but no type size or
               style is prescribed for the required information. See
               Appendix L of the attached Rule for examples of
           acceptable label formats. General Service
                 Incandescent Lamps principal display panel   The number of lamps included in
               the package, if more than one.The design voltage of the lamps,
               if it is other than 120 volts.The light output of each lamp
               included in the package, expressed in average
               initial lumens.The electrical power (energy used)
               of each lamp included in the package, expressed
               in average initial wattage.
             The life of each lamp included in
               the package, expressed in hours. The terms light output, energy used, and life must be used and must appear in
             that order and with equal clarity and conspicuousness.
             In addition, The light output, energy used, and
               life ratings must be listed in terms of lumens, watts, and hours, respectively. Each of the lumens, watts, and
               hours rating numbers must appear in the same type
               style and size. The words light output, energy
                 used, and life must appear before and
               be as conspicuous as the rating numbers and the
               words lumens, watts, and hours.
             The letters of the wordslumens, watts, and hours must be about
               half the size of the letters used for the words, light
                 output, energy used, andlife,
               respectively. For incandescent lamps that operate
             with multiple filaments, the light output and wattage at
             each level of operation and the lamp’s life,
             measured on the basis of the filament that fails first,
             must be disclosed. These disclosures must be based on the
             operation of the lamp at 120 volts, regardless of the
             lamp’s design voltage. If the lamp’s design
             voltage is not 120 volts, each disclosure of light
             output, wattage, and life must be followed by the words at
               120 volts.The following statement also must
             appear on the principal display panel of the package: To save energy costs,
                   find the bulbs with the light output you
                   need, then choose the one with the lowest
                   watts. Compact Fluorescent
             Lamps The required disclosures for
               general service incandescent lamps must be on package
               labels of medium screw base compact fluorescent lamps as
               well.For these products, light output must
                 be measured at a base-up position. If the manufacturer or
                 private labeler believes that the light output at a
                 base-down position would be more than five percent
                 different, the light output at the base-down position
                 also must be stated on the label. If no test data for the
                 base-down position exist, the fact that the light output
                 might be more than 5 percent different at a base-down
           position must be stated. Incandescent Reflector
                   Lamps may   To save energy costs,
                   find the bulbs with the [beam spread and]
                   light output you need, then choose the one
                   with the lowest watts. The label for incandescent reflector
             lamps must contain the capital letter "E"
             printed within a circle, followed by an asterisk (*) and
        this statement :* encircled Emeans this bulb
               meets Federal minimum efficiency standards. If that
             statement is not made on the principal display panel, the
        asterisk must be followed by this statement: *See [back, top, side] panel for
        details. General Service
                 Fluorescent Lamps  * encircled Emeans this bulb
             meets Federal minimum efficiency standards.If that statement is not made on the
             principal display panel, the asterisk must be followed by
             this statement: *See [back, top, side] panel for
             details.If a manufacturer or private labeler
             does not package or put labels on general service
             fluorescent lamps, these disclosure requirements can be
           met by permanently marking the lamp with the encircled E. The encircled E must appear in
             color-contrasting ink and it must appear in a typeface as
             large as either the manufacturer’s name or logo or
             another logo disclosed on the label, such as the UL,
           CBM,or ETLlogos. It is not necessary for the labels
             for general service fluorescent lamps to include the
             disclosures that are required on labels for incandescent
             and compact fluorescent lamps.  [back to top] Requirements
             for All Cartons of Covered Lamp Products Shipped within
             our Imported into The U.S. Section 305.11(e)(4) of
             the Rule requires the following statement on cartons of
             covered lamp products that are shipped within or imported
             into the U.S.: These lamps comply with
                 Federal energy efficiency labeling requirements. [back to top] Requirements
             for Promotional Materials Displayed or Distributed at the
             Point of Sale Section 305.13(a)(3) of the Rule
             includes additional requirements for manufacturers,
             private labelers, importers, distributors, or retailers
             who prepare printed material for display or distribution
             at the point of sale.If a representation is made about the
             cost to operate a covered lamp, information must be
             provided about how the figure was determined. This
             information may include purchase price, unit cost of
             electricity, hours of use, and patterns of use. These
             disclosures must be clear and conspicuous on the printed
             material near the representation about the cost of
             operation. [back to top] Requirements
             for Catalogs Section 305.14(c) of the Rule details
             the disclosure requirements for lamp products sold
             through catalogs; section 305.2(m) defines catalog.
             Each page of a catalog that lists a
             covered compact fluorescent lamp or general
               service incandescent lamp (reflector and
             non-reflector) must include all the information required
             on the package label — except the number of units in
             the package. This includes the disclosures of light
             output, energy used, life, and the design voltage, if it
             is other than 120 volts. The following information must comply
             with the format provisions of section 305.11(e)(1)(ii): the light output, energy used,
               and life disclosures must appear together
               in the catalog, in that order; they must be
               equally clear and conspicuous;the light output, energy used,
               and life disclosures must be made in terms
               of lumens, watts, and hours, respectively;the lumens, watts, and hours rating numbers must appear in the same type style
               and size, and each of the words lumens, watts,
               and hours must appear in the same type
               style and size; and
             the words light output, energy
               used, and life must precede and be as
               conspicuous as both the rating numbers and the
               words lumens, watts, and hours.
               However, the letters of the words lumens,
                 watts, and hours must be approximately
               half the size of those used for the words light
                 output, energy used, andlife,
               respectively. The disclosures do not have to comply
             with these format requirements if the catalog is not
             distributed to consumers who are making purchases for
             personal use. For all types of catalogs: On each page that lists a covered general
               service fluorescent lamp or an incandescent
                 reflector lamp, the required by section
               305.11(e)(2) must be disclosed like this: The encircled E must appear with each lamp entry andThe statement about the
                 meaning of the encircled E must appear at least once on the page.
               If the catalog contains
                 representations about the cost to operate a
                 covered lamp product, it must provide
                 information about how the cost was
                 determined. This information may include
                 purchase price, unit cost of electricity,
                 hours of use, and patterns of use. These
                 disclosures must be made clearly and
                 conspicuously and must be placed close to the
                 operating cost representation. [back to top] Testing
             and Sampling Requirements Manufacturers or private labelers must
             test samples of their products as the basis for the
             required disclosures, using certain procedures. Section
             305.5(b) of the Rule details the testing requirements.The following disclosures must be
             supported by competent and reliable scientific tests: For covered medium screw base
               compact fluorescent lamps and general service
               incandescent lamps (both reflector and
               non-reflector lamps), disclosures of design
               voltage, wattage, light output, and life.
             For covered general service
               fluorescent lamps and incandescent reflector
               lamps, the encircled E. The Rule does not require the use of
             specific test procedures, but section 305.5(b) lists
             certain test protocols that the FTC will accept.You must use competent and reliable
             scientific sampling procedures to choose samples for
             testing. The sampling requirements for selecting test
             specimens are included in section 305.6(b) of the Rule. The Rule does not require use of a
               specific sampling procedure, but section 305.6(b)
               states that the FTC accepts "Military
               Standard 105 - Sampling Procedures and Tables for
               Inspection by Attributes." [back to top] Record
             Keeping Requirements Section 305.15(a) requires that
             manufacturers and private labelers keep records for two
             years after production of the specific lamp product has
             ended. These records must show a reasonable basis —
             consisting of competent and reliable scientific tests
             — for the accuracy of the required disclosures on
             labels and in catalogs. [back to top] Submission
             of Test Date Records Section 305.15(b) requires that a
             manufacturer or private labeler submit to the Commission,
             within 30 days of a request from the Commission, the test
             data supporting the required disclosures. [back to top] Supplying
             Specimens for Testing By a Laboratory Designated by the
             FTC Section 305.16 requires that, if the
             FTC requests, a manufacturer of a covered product must
             supply up to two models of each lamp product to a
             laboratory chosen by the FTC to determine whether the
             disclosures comply with applicable standards. The FTC
             will pay for this testing. This process would occur only
             after the FTC examined the supporting test data provided
             by the manufacturer, as required by section 305.15, and
             after the manufacturer has had a chance to replicate test
             results. [back to top] Questions and Answers The following questions and answers may help you comply with the Rule: Q: Does the Rule require that the disclosures be made on
             labels in a specific type size or print style? A: No. The Rule does not specify type size or style of print for
             the required disclosures. However, it does require that the information be disclosed
             clearly and conspicuously, in a certain order, and according to a specific relative size
             relationship. For general service fluorescent lamps, the Rule has two additional
             requirements. First, the encircled E must appear on the label in color-contrasting ink. Second, it must appear in a typeface at
             least as large as the largest logo on the label, whether it’s the manufacturer’s
             name or logo or another logo, such as the UL, CBM, or ETL logos. Q: Where must the disclosures appear on the product package? A: The basic disclosures must appear on the principal display
             panel — the main location for information on the product package. However, certain
             disclosures may be made on a side or back panel if that location is noted clearly and
             conspicuously on the principal display panel. Q: Does the Rule require that the disclosures on the package be
               included inside a lined box or boxes on the principal display panel, as shown in the
             illustrations in the Rule? A: No. The illustrations included in the Rule, which show the
             disclosures inside lined boxes, are just examples of permissible disclosure formats. Q: Does the Rule permit the listing of the lamp’s lumens, watts,
               or hours on the principal display panel in addition to the required
             "side-by-side" or "in the specified order" disclosures? A: Yes. If the manufacturer includes the required disclosures of
             light output (in lumens), energy used (in watts), and life (in hours) on the principal
             display panel in the order and manner required by section 305.11(e) of the Rule, the
             manufacturer may include one or more additional disclosures of any of those individual
             items on the principal display panel, or on other panels of the package. The additional
             disclosures need not be accompanied by all other required items each time they appear.
             However, the additional disclosures must appear as clearly and conspicuously as the
             required or principal disclosures. Whether they are made clearly and conspicuously is a
             factual question that will depend on factors such as if the separate disclosures are made
             in the same type style and size as the required disclosures, the print background colors,
             and the number of times the separate disclosures appear. Q: Does the required disclosure of the encircled E apply to compact fluorescent lamps? A: No. The encircled E disclosure
             applies only to lamp products for which there are Federal minimum energy efficiency
             standards: specified general service fluorescent lamps and incandescent reflector lamps. Q: May a manufacturer of private labeler add information on
               the product label about light output, energy used, or life of an incandescent lamp at a
             design voltage other than 120 volts? A:Yes. The Rule requires manufacturers and private labelers of
             incandescent lamps to disclose light output, energy used, and life of the lamp when it is
             operated at 120 volts, regardless of the lamp’s design voltage. However,
             manufacturers and private labelers may include the additional disclosures of the
             lamp’s light output, energy used, and life when it is operated at a design voltage of
             125 volts or 130 volts. These additional disclosures must include the voltage at which
             they apply (for example, Light Output 1710 Lumens at 125 volts), and they may appear on
             any panel of the package. If they appear on the principal display panel, the manufacturer
             or private labeler may make the required disclosures for operation of the lamp at 120
             volts on a side or back panel. However, this option imposes the following requirements: All panels of the package that claim light output, energy used, or life
               must identify the lamp as "125 volts" or "130 volts" as appropriate;
               and
             The principal display panel must include the following statement clearly
               and conspicuously: This product is designed for [125/130] volts. When used on the normal
                 line voltage of 120 volts, the light output and energy efficiency are noticeably reduced.
                 See [side/back] panel for 120 volt ratings. Q: Does the Rule require disclosures in advertisements? A: The Rule requires disclosures on labels and catalogs, and on
             point-of-sale materials that make cost of operation claims. The Rule does not require
             disclosures in advertisements and other promotional material. However, if an ad refers to
             the energy used or the efficiency of a lamp product for which the Department of Energy has
             prescribed a test procedure under section 323 of the Energy Policy and Conservation Act,
             the ad would be considered a violation of section 5(a)(1) of the FTC Act (unfair or
             deceptive act or practice) unless the advertised product has been tested properly and
               unless the ad fairly discloses the test results. Section 305.4(d) of the Rule states
             the requirements for advertising claims about energy use or efficiency. Q: Must manufacturers include the disclosures required by the
               Rule on labels of lamp products that are distributed and sold only to others who repackage
               the lamps with other products (such as a desk lamp fixture) for resale to consumers or
             other users? A: No. The Rule requires labeling on packaging only for covered
             lamp products that are distributed and sold to consumers or other users alone or in
             multiple unit packages of lamp products. Q: Must manufacturers or other sellers of products that
               include a lamp product — such as desk lamp fixtures — include the disclosures
             required by the Rule on labels of such products? A: No. The purpose of the Rule is to provide consumers with
             prepurchase information on certain bulbs and tubes so they can compare them and select the
             most energy efficient one that meets their needs. Consumers can use the disclosures on
             lamp product packages when they select replacement lamp products for desk lamp fixtures or
             other products. Q: Must manufacturers of covered lamps conduct substantiation testing
             every time they change components, production procedures or methods? A: Yes, if the change is likely to affect the lamp’s light
             output, wattage, or life. For example, if a manufacturer starts using a different ballast
             in its compact fluorescent lamp, the resulting lamp would be a new product. The
             manufacturer would be required to have and rely on a reasonable basis, consisting of
             competent and reliable scientific tests, to substantiate the required disclosures for the
             new lamp product. Q: Who should I contact if I suspect non-compliance with the
             FTC’s lamp labeling requirements, false or misleading claims, or fraudulent activity
             regarding the sale of lamp products? A: For More Information The FTC works for the consumer to prevent fraudulent, deceptive, and 
unfair practices in the marketplace and to provide information to 
businesses to help them comply with the law. To file a complaint or to get free information on consumer issues, visit ftc.gov
 or call toll-free, 1-877-FTC-HELP (1-877-382-4357); TTY: 
1-866-653-4261. The FTC enters Internet, telemarketing, identity theft, 
and other fraud-related complaints into Consumer Sentinel, a secure online database available to hundreds of civil and criminal law enforcement agencies in the U.S. and abroad. Your Opportunity to Comment The National Small Business Ombudsman and 10 Regional Fairness Boards
 collect comments from small businesses about federal compliance and 
enforcement activities. Each year, the Ombudsman evaluates the conduct 
of these activities and rates each agency's responsiveness to small 
businesses. Small businesses can comment to the Ombudsman without fear 
of reprisal. To comment, call toll-free 1-888-REGFAIR (1-888-734-3247) 
or go to www.sba.gov/ombudsman.
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