Product and Packaging Marking; Comparative and Endorsement Labeling: What Do the Consumer and the Regulator Need?

Jose Frazier Gomez & My Ton ECO-Asia Clean Development and Climate Program, Bangkok, Thailand 7 April 2009 Chennai, India

Product Marking & Labeling: Presentation Agenda

Covers: Mandatory and voluntary product information Standardized information, which can be mandatory and/or voluntary Specialized information: safety, certification Primarily consumer oriented, but also useful for regulators & purchasers

Marking & Labeling: Purpose

Depending on agency mission: Inform consumer: product X is better than product Y. Encourage consumer choice: Product A is energy efficient. Conformance with requirements: Product is safety tested. Meets commercial code: Product is registered with an agency.

Product Labeling: Definitions

Comparative labeling: presents the relative performance of a product. Endorsement labeling: presents some set level of performance. Product marking: A mark, icon or word/number the product to demonstrate compliance. Package marking: Specific, required information on the product package.

Review: Comparative Labeling

Typically aimed to inform the consumer of choices between competing products. Provides consumers with relative performance information:
Within the same product group (CFLs) Within a category (e.g., all lamps)

Review: Comparative Labeling

Advantages and disadvantages: Works well if comparing one characteristic (efficacy), Can be used to communicate some other parameters as well (lifetime, etc). May not be suitable if you want to compare many light sources.

Review: Endorsement Labeling

Typically used for the same product group and is aimed to either: Inform the consumer of best (or better) products. Can be based on independent testing. Often used by third party.

Review: Endorsement Labeling

Advantages and disadvantages: Allows for simple comparison of products (endorsed/not endorsed). Products must meet a set of criteria/performance levels to be endorsed. Choosing the right set of criteria and performance level can be difficult. Needs wide coverage to be useful.

Review: Product Marking

Typically used for regulators Indicates compliance. Not consumers oriented. Can give informed consumers confidence.

Review: Product Marking

Advantages and disadvantages: Simple, single purpose indicator. Can be used in international and/or regional trading and/or compliance. Applicable only if there is agreement on performance levels and/or mutual recognition of test results or marking schemes.

Review: Package Marking

Used to inform both consumers and regulators Range from simple: Watt, life, lumens To Complex: Color rendering, color temperature, mercury content Encompasses endorsement, comparative, and product marking and labeling (EU requirements) Trade information: Warranty, contacts

Brand Name: Model/Type: Lamp Specifications

1

Light Output

900
lumens

Power Consumption Efficacy

3

15
watts

60 8000
hours

lumens per watt

Average Life 2

For lamps of similar light output, higher efficacy means more energy savings
1

when tested at standard test conditions

rated average life at 50% failure 3

The Minimum Efficacy Set By The Government For This Type Of Lamp Is 50 LUMENS PER WATT.

CTRL NO. XXXX-XXXXXX

DEPARTMENT OF E N E R G Y PHILIPPINE S

Review: Package Marking

Advantages: Provides the most direct way to reach the intended audience Can influence the purchasing process Indicate appropriate applications

Review: Package Marking

Disadvantages: The required information may be beyond an average consumer It can be difficult to determine the intended audience (and vice versa) Lamps (and their packaging) are getting smaller while required information is expanding.

In Summary
There are no easy answers, or perfect label. Mixing of regulator or conformance mark and consumer label can be a difficult proposition.

In Summary
The following questions can help: Who and why? For whom is the label or mark intended for, and why? Benefit vs. cost? Is the benefit more than the cost to comply? Standards or information? Can minimum performance standards replace some of the requirements?

In Summary
The following questions can help: Endorse or inform? Endorsement label schemes can replace the need for complex information. Allowing for innovative communications? Manufacturers need space to present their own information. What about unintended consequences? A complex mark may not look as nice at 5 mm

In Summary
On a regional or international scale: Will creating a specific local requirement present a barrier to suppliers entering your market and increasing consumer costs? If harmonizing with an existing scheme can this scheme work for a product with so many performance criteria?

Thank you for your attention!

Questions? josefrazier@cleanenergyasia.net myton@cleanenergyasia.net