FTC Advertising Guide Needs Updating and Should Prohibit the Advertising of Non-EPA Fuel Economy Ratings
Washington, D.C. – Comments filed by consumer organizations today called for several changes to the Federal Trade CommissionÕs Fuel Economy Advertising Guide. Published, consistent and fully disclosed fuel economy ratings are a significant factor in the ability of consumers to make informed vehicle purchase decisions.
“Not only do consumers need a reliable and clear mechanism to assess fuel efficiency when shopping for a vehicle, but the presence of mileage ratings in the market provides a strong competitive incentive for fuel economy improvements overall,” said Jack Gillis, CFA’s Director of Public Affairs and author of The Car Book.
The consumer groups’ comment letter made a number of recommendations to the Federal Trade Commission, including:
- Require EPA fuel economy ratings in vehicle advertisements.
- Allow only the EPA combined fuel economy rating in advertising instead of the variety of different rating combinations currently allowed.
- Prohibit advertisers from using non-EPA fuel economy estimates in advertisements.
- Require posting of comparable fuel economy estimates for alternative fuel vehicles in advertisements.
By requiring the use of one type of estimate, instead of any of the three types of estimates, consumers will be able to make ready and accurate comparisons between advertised vehicles. While the EPA ratings are comparative estimates, the combined rating will most closely resemble what the consumer will actually experience.
Consumer groups also recommend AGAINST allowing advertisers to use non-EPA fuel economy estimates even when the source and methodology of those estimates are disclosed. Requiring that only EPA information be used in disclosures, as opposed to allowing non-EPA estimates in advertising, even those legitimately developed, would prevent comparison to the EPA rating and defeat the consumerÕs ability to compare advertised information.
The consumer groups’ comment letter also highlighted the need for comparable fuel economy information for alternative fuel vehicles, such as electric cars. Such competitive disclosure will promote improvements in those vehicles in the same way it promotes improvements in gasoline powered engines. The use of the current EPA methodology for electric vehicles, which develops a gallon per mile figure based on kilowatt hours used, enables comparison with gas powered vehicles in advertisements.
Joining the Consumer Federation of America on the comment letter were:
Arizona Consumers Council
Chicago Consumers Coalition
Citizens’ Utility Board of Oregon
Consumer Assistance Council
Consumer Federation of the Southeast
Consumers for Auto Reliability and Safety
Democratic Processes Center
Florida Consumer Action Network
Maryland Consumer Rights Coalition
Maryland Public Interest Research Group
Massachusetts Consumers’ Coalition
New Jersey Citizen Action
Oregon Consumer League
Virginia Citizens Consumer Council
Wisconsin Consumers League
A copy of the comments can be found at http://www.consumerfed.org/pdfs/fuel_economy_disclosure_comments.pdf or http://www.ftc.gov/os/comments/fueleconadguidepropamend/index.shtm.
The Consumer Federation of America (CFA) is a non-profit association of over 280 pro-consumer groups, with a combined membership of 50 million people. CFA was founded in 1968 to advance consumers’ interests through research, advocacy and education.