Notice2025-23079
Agency Information Collection Activities; Proposed Collection; Comment Request; Extension
Primary source
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Published
December 17, 2025
Issuing agencies
Federal Trade Commission
Abstract
The Federal Trade Commission (FTC or Commission) is seeking public comment on its proposal to extend for an additional three years the current Paperwork Reduction Act (PRA) clearance for information collection requirements contained in the FTC's Consumer Product Warranty Rule (Warranty Rule or Rule). The current clearance expires on April 30, 2026.
Full Text
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<title>Federal Register, Volume 90 Issue 240 (Wednesday, December 17, 2025)</title>
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[Federal Register Volume 90, Number 240 (Wednesday, December 17, 2025)]
[Notices]
[Pages 58557-58559]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-23079]
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FEDERAL TRADE COMMISSION
Agency Information Collection Activities; Proposed Collection;
Comment Request; Extension
AGENCY: Federal Trade Commission.
ACTION: Notice.
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SUMMARY: The Federal Trade Commission (FTC or Commission) is seeking
public comment on its proposal to extend for an additional three years
the current Paperwork Reduction Act (PRA) clearance for information
collection requirements contained in the FTC's Consumer Product
Warranty Rule (Warranty Rule or Rule). The current clearance expires on
April 30, 2026.
DATES: Comments must be received on or before February 17, 2026.
ADDRESSES: Interested parties may file a comment online or on paper, by
following the instructions in the Request for Comment part of the
SUPPLEMENTARY INFORMATION section below. Write ``Consumer Product
Warranty Rule; PRA Comment, P044403,'' on your comment, and file your
comment online at <a href="https://www.regulations.gov">https://www.regulations.gov</a> by following the
instructions on the web-based form. If you prefer to file your comment
on paper, mail your comment to the following address: Federal Trade
Commission, Office of the Secretary, 600 Pennsylvania Avenue NW, Mail
Stop H-144 (Annex E), Washington, DC 20580.
FOR FURTHER INFORMATION CONTACT: Sung W. Kim, Attorney, Division of
Marketing Practices, Bureau of Consumer Protection, Federal Trade
Commission, 600 Pennsylvania Avenue NW, Washington, DC 20580, (202)
326-2211; <a href="/cdn-cgi/l/email-protection#9ceff7f5f1aadcfae8ffb2fbf3ea"><span class="__cf_email__" data-cfemail="89fae2e0e4bfc9effdeaa7eee6ff">[email protected]</span></a>.
SUPPLEMENTARY INFORMATION:
Title: Rule Concerning Disclosure of Written Consumer Product
Warranty Terms and Conditions, 16 CFR part 701.
OMB Control Number: 3084-0111.
Type of Review: Extension of a currently approved collection.
Abstract: The Warranty Rule is one of three rules \1\ that the FTC
implemented pursuant to requirements of the Magnuson-Moss Warranty Act,
15 U.S.C. 2301 et seq. (Warranty Act or Act).\2\ The Warranty Rule
specifies the information that must appear in a written warranty on a
consumer product \3\ costing more than $15. The Rule tracks Section
102(a) of the Warranty Act,\4\ specifying information that must appear
in the written warranty and, for certain disclosures, mandates the
exact language that must be used.\5\ Neither the Warranty Rule nor the
Act requires that a manufacturer or retailer warrant a consumer product
in writing, but if they choose to do so, the warranty must comply with
the Rule.
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\1\ The other two rules relate to the pre-sale availability of
warranty terms and minimum standards for informal dispute settlement
mechanisms that are incorporated into a written warranty.
\2\ 40 FR 60168 (Dec. 31, 1975).
\3\ The definition of consumer product excludes products
purchased solely for commercial or industrial use. 16 CFR 701.1(b).
\4\ 15 U.S.C. 2302(a).
\5\ 40 FR 60168, 60169-60170.
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Estimated Annual Hours Burden: 209,048 hours.
Estimated Annual Labor Cost Burden: $28,977,188.
As required by Section 3506(c)(2)(A) of the PRA, 44 U.S.C.
3506(c)(2)(A), the FTC is providing this opportunity for public comment
before requesting that OMB extend the existing clearance for the
information collection requirements contained in the Warranty Rule.
Burden Statement
Total annual hours burden: 209,048 hours.
In its 2022 submission to OMB, the FTC estimated that the
information collection burden of including the disclosures required by
the Warranty Rule was 216,752 hours per year. Although the Rule's
information collection requirements have not changed, the current
estimate decreases the number of manufacturers subject to the Rule
based on recent Census data.\6\ Further, because most warrantors likely
would continue to disclose the information required by the Rule, even
if there were no statute or rule requiring them to do so, staff's
estimates likely overstate the PRA-related burden attributable to the
Rule. Moreover, the Warranty Rule has been in effect since 1976, and
warrantors have long since modified their warranties to include the
information the Rule requires.
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\6\ The Number of Firms and Establishments, Employment, and
Annual Payroll by State, Industry, and Enterprise Employment Size:
2022, release date: 4/10/2025, available at <a href="https://www.census.gov/data/tables/2022/econ/susb/2022-susb-annual.html">https://www.census.gov/data/tables/2022/econ/susb/2022-susb-annual.html</a>.
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Based on conversations with various warrantors' representatives
over the years, staff has concluded that eight hours per year is a
reasonable estimate of warrantors' PRA-related burden attributable to
the Warranty Rule. This estimate includes the number of hours
warrantors may need to ensure new warranties and any changes to
existing warranties comply with the Rule. Based on recent Census data,
staff now estimates that there are 26,131
[[Page 58558]]
manufacturers covered by the Rule.\7\ This results in an annual burden
estimate of approximately 209,048 hours (26,131 manufacturers x 8 hours
of burden per year).
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\7\ Because some manufacturers likely make products that are not
priced above $15 or not intended for household use--and thus would
not be subject to the Rule--this figure is likely an overstatement.
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Total annual labor costs: $28,977,188.
Labor costs are derived by applying appropriate hourly cost figures
to the burden hours described above. The work required to comply with
the Warranty Rule--ensuring that new warranties and changes to existing
warranties comply with the Rule--requires a mix of legal analysis
(50%), legal support (paralegals) (25%) and clerical help (25%). Staff
estimates that half of the total burden hours (104,524 hours) requires
legal analysis at an average hourly wage of $250 for legal
professionals,\8\ resulting in a labor cost of $26,131,000. Assuming
that 25% of the total burden hours requires legal support at the
average hourly wage of $32.60, and that the remaining 25% requires
clerical work at an average hourly wage of $21.86, the resulting labor
cost is approximately $2,846,188 ($1,703,741 + $1,142,447). Thus, the
total annual labor cost is approximately $28,977,188 ($26,131,000 for
legal professionals + $1,703,741 for legal support + $1,142,447 for
clerical workers).
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\8\ Staff has derived an hourly wage rate for legal
professionals based upon industry knowledge. The hourly wage rates
for legal support workers and for clerical support are based on mean
hourly wages available at <a href="https://www.bls.gov/news.release/ocwage.htm">https://www.bls.gov/news.release/ocwage.htm</a> (``Occupational Employment and Wages--May 2024,'' U.S.
Department of Labor, released April 2, 2025, Table 1 (``National
employment and wage data from the Occupational Employment Statistics
survey by occupation, May 2024'').
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Total Capital and Start-Up Costs
The Rule imposes no appreciable current capital or start-up costs
that businesses do not already spend in the normal course of business.
To comply with the Warranty Rule, warrantors need only the ordinary
office equipment to draft new warranties and to change the wording of
existing warranties to include the required disclosures. Thus,
compliance requires no capital equipment or special technology apart
from what the manufacturer or seller would already be using as part of
the normal course of business, such as computer or other word
processing equipment, and photocopying equipment. Similarly,
distribution of the warranty does not impose any special capital costs
apart from the packaging and printing equipment already in use by the
business. It is not possible to state with any precision what fraction
of the cost of that equipment could be attributed to distributing the
warranty.
Total Operation/Maintenance/Purchase of Services Costs
The only ongoing costs involved with compliance are those costs
associated with maintenance and repair of computer word processing and
photocopying equipment used to generate the warranty document that
contains the required disclosures. These are costs that the seller or
manufacturer already bears in the normal cost of business; it is
unlikely that Warranty Rule compliance would impose significant
incremental costs. Likewise, the cost of distributing warranty
information involves such things as the purchase of supplies (such as
paper), the maintenance of equipment, or the purchase of services to
print, package, and distribute the warranty. These are costs that would
be already built into the packaging and distribution of the product
itself and which are already assumed as part of the normal course of
business.
Request for Comments
Pursuant to Section 3506(c)(2)(A) of the PRA, the FTC invites
comments on: (1) whether the information collection requirements are
necessary, including whether the information will be practically
useful; (2) the accuracy of our burden estimates, including whether the
methodology and assumptions used are valid; (3) ways to enhance the
quality, utility, and clarity of the information to be collected; and
(4) ways to minimize the burden of the collection of information.
For the FTC to consider a comment, we must receive it on or before
February 17, 2026. Your comment, including your name and your state,
will be placed on the public record of this proceeding, including the
<a href="https://www.regulations.gov">https://www.regulations.gov</a> website.
You can file a comment online or on paper. Due to heightened
security screening, postal mail addressed to the Commission will be
subject to delay. We encourage you to submit your comments online
through the <a href="https://www.regulations.gov">https://www.regulations.gov</a> website.
If you file your comment on paper, write ``Regulation V, subpart N;
PRA Comment, P085405,'' on your comment and on the envelope, and mail
it to the following address: Federal Trade Commission, Office of the
Secretary, 600 Pennsylvania Avenue NW, Mail Stop H-144 (Annex E),
Washington, DC 20580.
Because your comment will become publicly available at <a href="https://www.regulations.gov">https://www.regulations.gov</a>, you are solely responsible for making sure that
your comment does not include any sensitive or confidential
information. In particular, your comment should not include any
sensitive personal information, such as your or anyone else's Social
Security number; date of birth; driver's license number or other state
identification number, or foreign country equivalent; passport number;
financial account number; or credit or debit card number. You are also
solely responsible for making sure that your comment does not include
any sensitive health information, such as medical records or other
individually identifiable health information. In addition, your comment
should not include any ``trade secret or any commercial or financial
information which . . . is privileged or confidential''--as provided by
Section 6(f) of the FTC Act, 15 U.S.C. 46(f), and FTC Rule 4.10(a)(2),
16 CFR 4.10(a)(2)--including, in particular, competitively sensitive
information, such as costs, sales statistics, inventories, formulas,
patterns, devices, manufacturing processes, or customer names.
Comments containing material for which confidential treatment is
requested must (1) be filed in paper form, (2) be clearly labeled
``Confidential,'' and (3) comply with FTC Rule 4.9(c). In particular,
the written request for confidential treatment that accompanies the
comment must include the factual and legal basis for the request, and
must identify the specific portions of the comment to be withheld from
the public record. See FTC Rule 4.9(c). Your comment will be kept
confidential only if the General Counsel grants your request in
accordance with the law and the public interest. Once your comment has
been posted publicly at <a href="http://www.regulations.gov">www.regulations.gov</a>, we cannot redact or remove
your comment unless you submit a confidentiality request that meets the
requirements for such treatment under FTC Rule 4.9(c), and the General
Counsel grants that request.
The FTC Act and other laws that the Commission administers permit
the collection of public comments to consider and use in this
proceeding as appropriate. The Commission will consider all timely and
responsive public comments that it receives on or before February 17,
2026. For information on the Commission's privacy policy, including
routine uses permitted by the Privacy Act, see
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<a href="https://www.ftc.gov/site-information/privacy-policy">https://www.ftc.gov/site-information/privacy-policy</a>.
Josephine Liu,
Assistant General Counsel for Legal Counsel.
[FR Doc. 2025-23079 Filed 12-16-25; 8:45 am]
BILLING CODE 6750-01-P
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