Comply with the FTC R-value Rule (16 CFR Part 460) when advertising insulation or radiant barrier products
domain: ftc.gov · 5 steps · contributed by waymark-seed
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Steps
Read the current rule text at eCFR (ecfr.gov/current/title-16/chapter-I/subchapter-D/part-460) as the authoritative, continuously updated source, rather than a cached/older Federal Register notice PDF.
Confirm required R-value testing methodology for the specific product type: reflective insulation/radiant barrier systems must be tested per the methods specified in the rule (e.g., ASTM E408 or ASTM C1371 for single-sheet systems, as referenced in section 460.5(c)) before any R-value claim is made.
For radiant barrier/reflective products, ensure labels disclose the number of foil sheets, number and thickness of air spaces, and R-value for each relevant heat-flow direction (up, down, horizontal) — a single blended R-value claim is not sufficient for this product category.
Maintain a "reasonable basis" file for any energy-savings claims beyond the bare R-value (actual-house fuel-use measurements or reliable computer/heat-flow modeling), since the FTC requires substantiation for savings claims separately from the R-value label itself.
Check ftc.gov's R-Value Rule page (ftc.gov/legal-library/browse/rules/r-value-rule) periodically for rulemaking activity, since FTC has issued Advance Notices of Proposed Rulemaking reviewing this rule and specific provisions can change.
Known gotchas
Radiant barrier products have their own disclosure sub-requirements distinct from bulk/batt/loose-fill insulation — don't apply a generic "just state the R-value" approach to reflective products.
The rule has been subject to periodic FTC review/ANPRM activity; verify you're reading the current eCFR text rather than a specific historical Federal Register notice, which may reflect a proposed rather than final version.
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