Audioholics Petition to FTC to Reopen 2024 Amplifier Rule - We Need Your Help!

[gene]

This petition urges the FTC to reconsider its August 2024 Final Amplifier Ruling (16 CFR Part 432), which expands regulation of power output claims to ALL audio products, including powered speakers, soundbars, and subwoofers. The ruling aims to standardize comparisons for consumers but diverges from prior guidelines by including closed systems and not mandating testing for multi-channel outputs or 4-ohm ratings. It applies retroactively to products made before the ruling, which could significantly impact manufacturers. This broader scope and lack of specific testing standards could create severe complications for the electronics industry, potentially disrupting manufacturing processes and leading to widespread compliance challenges.

Read: Audioholics Petition to FTC To Reopen 2024 Amplifier Rule

This petition urges readers and our YouTube audience to ask the FTC to reconsider its Final Amplifier Ruling of August 2024 (16 CFR Part 432)

Comments on CTA’s petition are due to the FTC by November 8, 2024.

To submit comments, visit the FTC Comment Page. You may attach your comments as a PDF or Word document, or enter them into the provided text box.

Please mention that you would like this rule to be reopened to consider the technical issues raised by Audioholics.com and the CTA in an effort to more accurately rate amplifier power and the maximum SPL performance of powered loudspeaker systems.

You can also feel free to reach out to: Hong Park, hpark@FTC.gov

 

[PENG]

Gene, many thanks for doing this, I hope enough people will take the time to comment and force some positive results eventually.

 

[Eppie]

Submission successful. Thanks Gene for your continued efforts on this.

 

[gene]

I'm shocked more people aren't commenting on this article given the implications and how this can really wreck havoc in our industry. some key points I hope to drive further in case they were missed in the editorial:

• The original FTC Amplifier Rule of 1974 did specify full bandwidth testing from 20Hz to 20kHz, but did it allow manufacturers to specify THD+N and load impedance.
• In 2000, three parameters for rating amplifier power—load impedance, rated power bandwidth or frequency response, and total harmonic distortion (THD)—were removed from the mandate in media advertising only, which I believe led to inflated power ratings in AV receivers and HTIB-type products. Hence our Truth in Power Movement that exposed this problem.
• The FTC never enforced the 5-minute amplifier test rule, leading many manufacturers to determine their own methods for testing maximum continuous power.
• In 2020, the FTC considered dropping the Amplifier Rule, but our petition efforts helped gather 1,130 signatures, keeping the rule in place.
• No FTC Amplifier Rule addressed powered speakers as early as 1990 but allowed for amplifiers to be tested for the impedance they were designed.
• The new 2024 Rule has major implications for how manufacturers specify maximum continuous power, as it now mandates a 5-minute test at a specific THD+N of 1% from 20Hz to 20kHz into an 8-ohm load.
• The new 2024 Rule doesn’t allow for low-impedance power testing of closed systems like powered speakers or subwoofers. It skirts around the issues of bandwidth and load impedance, even if a closed system’s impedance is much lower than 8 ohms.
• The new 2024 FTC Rule doesn’t treat closed systems fairly by not factoring in system efficiency, impedance, and bandwidth. Instead of focusing on clean SPL output, it solely focuses on maximum amplifier power into 8 ohms regardless of system impedance that is presented to the amplifier.
• The new 2024 FTC Rule doesn’t mandate manufacturers to specify maximum continuous power; they can still specify power as they see fit, as long as it doesn’t claim to be maximum or continuous RMS power.
• The new 2024 FTC Amplifier Rule doesn’t address how to test multi-channel amplifiers with more than two channels.
• The new 2024 FTC Amplifier Rule is retroactive on products manufactured before August 2024, when the rule went into effect. This could have serious implications for products that were tested without adherence to the new rule.
• The new 2024 FTC Amplifier Rule doesn’t specify how to conduct the 5-minute test, whether with a single tone or sweep. This ambiguity may cause some amplifiers, particularly Class D models, to enter protection mode or limit power to preserve the output filter.
• The new 2024 FTC Amplifier Rule limits the maximum continuous power output to what the amplifier can deliver at 20kHz in most cases. This contrasts with the energy demands of real program material, such as music or cinema.
• The new 2024 FTC Amplifier Rule tests amplifiers in ways that don’t align with typical consumer usage, potentially forcing manufacturers to make compromised design choices just to comply with the rule.

 

[TLS Guy]

I'm shocked more people aren't commenting on this article given the implications and how this can really wreck havoc in our industry. some key points I hope to drive further in case they were missed in the editorial:

• The original FTC Amplifier Rule of 1974 did specify full bandwidth testing from 20Hz to 20kHz, but did it allow manufacturers to specify THD+N and load impedance.
• In 2000, three parameters for rating amplifier power—load impedance, rated power bandwidth or frequency response, and total harmonic distortion (THD)—were removed from the mandate, which led to inflated power ratings in AV receivers and HTIB-type products. Hence our Truth in Power Movement that exposed this problem.
• The FTC never enforced the 5-minute amplifier test rule, leading many manufacturers to determine their own methods for testing maximum continuous power.
• In 2020, the FTC considered dropping the Amplifier Rule, but our petition efforts helped gather 1,130 signatures, keeping the rule in place.
• No FTC Amplifier Rule ever addressed powered speakers until the 2024 Final Amplifier Rule.
• The new 2024 Rule has major implications for how manufacturers specify maximum continuous power, as it now mandates a 5-minute test at a specific THD+N of 1% from 20Hz to 20kHz into an 8-ohm load.
• The new 2024 Rule doesn’t allow for low-impedance power testing of closed systems like powered speakers or subwoofers. It skirts around the issues of bandwidth and load impedance, even if a closed system’s impedance is much lower than 8 ohms.
• The new 2024 FTC Rule doesn’t treat closed systems fairly by not factoring in system efficiency, impedance, and bandwidth. Instead of focusing on clean SPL output, it solely focuses on maximum amplifier power into 8 ohms regardless of system impedance that is presented to the amplifier.
• The new 2024 FTC Rule doesn’t mandate manufacturers to specify maximum continuous power; they can still specify power as they see fit, as long as it doesn’t claim to be maximum or continuous RMS power.
• The new 2024 FTC Amplifier Rule doesn’t address how to test multi-channel amplifiers with more than two channels.
• The new 2024 FTC Amplifier Rule is retroactive on products manufactured before August 2024, when the rule went into effect. This could have serious implications for products that were tested without adherence to the new rule.
• The new 2024 FTC Amplifier Rule doesn’t specify how to conduct the 5-minute test, whether with a single tone or sweep. This ambiguity may cause some amplifiers, particularly Class D models, to enter protection mode or limit power to preserve the output filter.
• The new 2024 FTC Amplifier Rule limits the maximum continuous power output to what the amplifier can deliver at 20kHz in most cases. This contrasts with the energy demands of real program material, such as music or cinema.
• The new 2024 FTC Amplifier Rule tests amplifiers in ways that don’t align with typical consumer usage, potentially forcing manufacturers to make compromised design choices just to comply with the rule.

I am getting my comments ready. This is bureaucratic ignorance at its worst.

 

[paulgyro]

Done! My formatting was butchered but here is what I submitted for those who might want to do this easy via copy/paste.

"Please reopen this rule to consider the technical issues raised by Audioholics.com and the CTA in an effort to more accurately rate amplifier power and the maximum SPL performance of powered loudspeaker systems. 1) I believe it is prudent that the FTC reopen the Amplifier Rule proceeding and seek comment on an alternative testing procedure that better reflects real world use. 2) The FTC should establish, either through rulemaking, or a formal staff opinion, an exemption that allows active speaker amplifiers to be rated at the load impedance of the drivers they are paired with. 3) I support CTA’s (https://cdn.cta.tech/cta/media/media/pdfs/amplifier-rule-petition-for-clarification-or-amendment-final.pdf) petition seeking to clarify the Commission’s application of the amended Trade Regulation Rule Relating to Power Output Claims for Amplifiers Utilized in Home Entertainment Products to products designed, tested, and manufactured before the amended Rule’s August 12, 2024 effective date. 4) I also support CTA’s (https://cdn.cta.tech/cta/media/media/pdfs/amplifier-rule-petition-for-clarification-or-amendment-final.pdf) request for a stay of enforcement until the Commission has addressed the issues raised by this petition. "

 

[gene]

I am getting my comments ready. This is bureaucratic ignorance at its worst.

I made a couple of corrections to my bulleted summary above after discussing with Dennis Murphy. I haven't yet submitted to the FTC as I'm busying working on a YT video now. But, I will be making an official request as well. thanks

 

[gene]

I just sent this email to Mr. Hong Park from the FTC

Dear Mr Hong Park;

I wanted to make you aware that I’ve authored this article to Petition the FTC to Reopen the August 2024 Final Amplifier Rule:

https://www.audioholics.com/audio-amplifier/ftc-final-amplifier-rule-2024

In this article, I highlight all of the issues concerning the new Amplifier Rule.

I also attached a PowerPoint Presentation I will be presenting on our Youtube channel ( www.Youtube.com/Audioholics).

You may or may not be aware that I petitioned the FTC To keep the Rule alive back in 2021 both editorially and on our Youtube channel.

https://www.audioholics.com/audio-amplifier/ftc-amplifier-rule-help-protect-home-audio-consumers-today

This coverage was largely responsible for generating 1,130 comments and documented 550 unique responses that followed.

I hope the FTC will strongly consider our request so that we can assist in making positive changes to the next revision that would benefit consumers, manufacturers, and retailers alike. Thank you for your consideration.

 

[Swerd]

I made a couple of corrections to my bulleted summary above after discussing with Dennis Murphy. I haven't yet submitted to the FTC as I'm busying working on a YT video now. But, I will be making an official request as well. thanks

Thanks Gene for taking this on. I'm glad you could discuss this with Dennis. His opinion & knowledge of the FTC's past decisions about this are important to know.

For those who don't know, Dennis Murphy was an economist who worked his whole career at the FTC. Until he retired a number of years ago, he used to be their guy for amplifier ratings & regulations. I had discussed this subject with Dennis some time ago and, if I remember correctly, I got these impressions:

1. In the 1970s during the so-called amplifier ratings wars, the public's reaction to this issue was far greater than it is now.
2. In the FTC's opinion, there is more competition among receiver & amp makers than there was in the 1970s. As a result, the FTC was less inclined to regulate this matter any further.
3. More recently, the FTC has been much less concerned with deceiving amp power ratings than it is by internet fraud committed by hackers on banks, public institutions (such as hospitals) & individuals.

Even though we on AH think this is a big problem, the FTC doesn't. Maybe Dennis has changed his mind about this since we talked about it years ago.

 

[highfigh]

I'm shocked more people aren't commenting on this article given the implications and how this can really wreck havoc in our industry. some key points I hope to drive further in case they were missed in the editorial:

• The original FTC Amplifier Rule of 1974 did specify full bandwidth testing from 20Hz to 20kHz, but did it allow manufacturers to specify THD+N and load impedance.
• In 2000, three parameters for rating amplifier power—load impedance, rated power bandwidth or frequency response, and total harmonic distortion (THD)—were removed from the mandate in media advertising only, which I believe led to inflated power ratings in AV receivers and HTIB-type products. Hence our Truth in Power Movement that exposed this problem.
• The FTC never enforced the 5-minute amplifier test rule, leading many manufacturers to determine their own methods for testing maximum continuous power.
• In 2020, the FTC considered dropping the Amplifier Rule, but our petition efforts helped gather 1,130 signatures, keeping the rule in place.
• No FTC Amplifier Rule addressed powered speakers as early as 1990 but allowed for amplifiers to be tested for the impedance they were designed.
• The new 2024 Rule has major implications for how manufacturers specify maximum continuous power, as it now mandates a 5-minute test at a specific THD+N of 1% from 20Hz to 20kHz into an 8-ohm load.
• The new 2024 Rule doesn’t allow for low-impedance power testing of closed systems like powered speakers or subwoofers. It skirts around the issues of bandwidth and load impedance, even if a closed system’s impedance is much lower than 8 ohms.
• The new 2024 FTC Rule doesn’t treat closed systems fairly by not factoring in system efficiency, impedance, and bandwidth. Instead of focusing on clean SPL output, it solely focuses on maximum amplifier power into 8 ohms regardless of system impedance that is presented to the amplifier.
• The new 2024 FTC Rule doesn’t mandate manufacturers to specify maximum continuous power; they can still specify power as they see fit, as long as it doesn’t claim to be maximum or continuous RMS power.
• The new 2024 FTC Amplifier Rule doesn’t address how to test multi-channel amplifiers with more than two channels.
• The new 2024 FTC Amplifier Rule is retroactive on products manufactured before August 2024, when the rule went into effect. This could have serious implications for products that were tested without adherence to the new rule.
• The new 2024 FTC Amplifier Rule doesn’t specify how to conduct the 5-minute test, whether with a single tone or sweep. This ambiguity may cause some amplifiers, particularly Class D models, to enter protection mode or limit power to preserve the output filter.
• The new 2024 FTC Amplifier Rule limits the maximum continuous power output to what the amplifier can deliver at 20kHz in most cases. This contrasts with the energy demands of real program material, such as music or cinema.
• The new 2024 FTC Amplifier Rule tests amplifiers in ways that don’t align with typical consumer usage, potentially forcing manufacturers to make compromised design choices just to comply with the rule.

What does Europe require?

Point 1- "did it allow specifying the impedance? It required that.

The attachment is for an amplifier I owned and it was released in 1977- shows more than basic specs, but it was at a time when manufacturers were still BS-ing their way through the market.

 

[gene]

Guys, please submit your petition to the link below rather than emailing Hong Park:

Regulations.gov

www.regulations.gov

Mr. Park contacted me that he wants to ensure the petitions get on record and this is the best way to do it. Thanks

 

[gene]

 

[Verdinut]

Since most of currently built loudspeaker drivers have a 4 ohm typical impedance, IMO the new FTC rule should require amplifier manufacturers to specify the rated power output for both 8 and 4 ohm loads between 20 and 10 kHz.

With regard to THD at 20 kHz, I don't see the need for this specification at such frequency. Once I read an article that suggested limiting such spec to 10 kHz, as no human being can hear 20 kHz anyway. I think that should be sufficient for all practical purposes.

Is there a spec requirement for SMPTE IM distortion? That's also an important performance factor.

I'm planning to have my comments added to the petition.

 

[Slave IV]

Thanks for sharing this and I'd be happy to comment.
Also, not playing down the importance for most people but most reputable companies either already conservatively rate their products, or I am able to find third party tests to confirm specs of a product will meet my needs so this has never been an issue for me personally.