Energy Labeling Rule
The Federal Trade Commission (FTC or Commission) seeks public comment on potential amendments to the Energy Labeling Rule (Rule), including energy labels for several new consumer product categories, and other possible amendments to improve the Rule's effectiveness and reduce unnecessary burdens.
What this rule actually says
The FTC is considering updating rules about energy labels—those yellow stickers on appliances showing how much electricity they use. The agency is asking for feedback on whether to extend these labels to new product categories and make other changes to the existing rule. This is a *proposed* rule, meaning it's still in the comment phase and hasn't been finalized yet.
Who it applies to
- If you sell physical hardware (like smart thermostats, AI-powered monitoring devices, or edge computers that run locally): this *might* eventually apply.
- If you only offer software/cloud services (AI medical scribes, hiring assistants, support chatbots): this almost certainly does not apply to you.
- Jurisdiction: US only (FTC authority).
- Data scope: Not relevant—this rule is about energy consumption, not data collection or privacy.
The key question: does your product consume meaningful electricity in a way consumers care about? A cloud-based chatbot running on someone else's servers? No. A physical device that plugs in or uses batteries? Potentially yes, but only if it ends up in a newly regulated category.
What founders need to do
- Check if you make hardware (1 hour). If your product is 100% software, stop here. If you make devices, move to step 2.
- Monitor the rule's status (ongoing, minimal effort). The FTC is still collecting comments on what categories to include. Check regulations.gov periodically or set a Google Alert for "Energy Labeling Rule" to catch when it's finalized.
- Review the final rule when published (2–3 hours, one-time). Once the FTC issues its final rule, scan it to see if your specific product type is listed. Most hardware today already requires labels; the question is whether *your* category is newly covered.
- If your hardware is newly regulated (1–2 weeks). Work with your supplier or manufacturer to obtain EnergyGuide labels or equivalent disclosures. Your manufacturing partner often handles this.
- Update product pages and packaging (1–2 days). Add required energy labels to your website, packaging, and retailer listings.
Bottom line
Ignore this for now unless you're selling physical hardware—and even then, wait for the final rule before acting, since it's still proposed.