Comments to the FTC on the Appliance Labeling Rule

Regulatory Filing


ACEEE conducted a multi-method, sequential research project to evaluate the effectiveness of the current EnergyGuide label and alternate label designs. Seven studies were conducted in total, the first with supply side actors, and the remainder with consumers. Supply-side actors (e.g., manufacturers, contractors, and retail sales staff) were interviewed to uncover opinions regarding program efficacy and the optimal label format. Primary research with consumers sought to determine the best label format and informational elements for U.S. consumers. The consumer studies culminated in a quasi-real world shopping experience. ACEEE staff and contractors conducted interviews with supply-side actors and consumers; an independent market research firm conducted the remainder of the qualitative research and all quantitative research.

Our research found that, although each group of market players are used to and familiar with the current EnergyGuide label, there appears to be a low level of use and, on the supply side, perceived value. Most importantly, the current label also appears to have minimal impact on consumer, manufacturer, and contractor comparisons and choices. Indeed, when the current label was not identified as such, most consumers were unable to identify it or correctly select it from a group of different label designs despite the fact that most had recently purchased an appliance or were currently shopping for one. Findings provide strong evidence that the EnergyGuide can be redesigned to improve consumer comprehension, encourage wider use of the label, and motivate consumers to consider energy use when purchasing a labeled appliance.