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AHRI Submits Comment on FTC Labeling NOPR

On Jan. 11, AHRI submitted comments on a Federal Trade Commission (FTC) notice of proposed rulemaking (NOPR), which was published on Nov. 2, 2015. The NOPR included modified central air conditioner (CAC) and residential water heater EnergyGuide labels, and a requirement to report links to EnergyGuide labels for all products through the DOE’s Compliance and Certification Management System.

In the comments, AHRI explained that the AHRI Directory of Certified Product Performance already provides a link to download FTC EnergyGuide labels. AHRI requested that the FTC allow the submission of a link to a download and to clarify it in the final rule. Regarding the CAC label, AHRI supported the FTC’s proposal to revise the map for regional standards. The FTC had also proposed to remove the range of efficiencies by matched coil and only list the lowest matched efficiency. AHRI requested that the range remain on the label, as it is a recent addition and more clearly conveys the actual efficiency of the product. Regarding water heater labels, the FTC proposed a revised label for the updated DOE test procedure and did not include the AHRI-proposed label in this NOPR. In its comments, AHRI again suggested using its proposed label, and requested a delay in the implementation of a new labels until after DOE has issued a final rule for the conversion factor to the new test procedure.

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