Is the EnergyGuide sticker accurate?
The yellow sticker costs everything at 14¢ a kilowatt-hour. Two federal agencies now disagree about that number.
Every figure below is computed from the catalogue, not written by hand · updated October 19, 2026
What the sticker assumes
The yellow EnergyGuide label is not an estimate of your bill and was never meant to be read as one. It is a fixed sum: the energy the model used on a federal test, multiplied by a single national electricity price that is written into the regulation itself.
That price is 14¢ per kWh. It is not a forecast and not an average the manufacturer chose — it is a figure listed in Appendix K1 of the FTC's Energy Labeling Rule, and §305.8(b) requires the cost “to be used on labels” to be that one. It replaced 12¢ in January 2023, and it was derived from Department of Energy figures for 2022.
So every sticker in every showroom today is doing its arithmetic with the price of electricity as it stood four years ago, and will keep doing so until the Commission publishes revised figures, which it says it will do in 2027.
16 CFR Part 305, Appendix K1, the table of representative unit costs the rule requires labels to use.
The government already published a newer number
This is the part that makes the gap something other than ordinary inflation. The Department of Energy publishes its own representative average unit costs every year, and on March 26, 2026 it put electricity at 17.22¢ per kWh, effective April 27, 2026. That notice says in terms that these costs “are also used to comply with Federal Trade Commission (FTC) requirements for labeling”.
In the same notice it says manufacturers are required to use the revised figures when the FTC publishes new ranges of comparability. The FTC has not published them. So the newer number is current, official and binding on nobody's label.
Two federal agencies are holding two different answers to the same question — 17.22¢ and 14¢ — and the sticker prints the older one. Nobody has made a mistake. The lag is the handover between them, and it is scheduled to close in 2027.
Energy Conservation Program for Consumer Products: Representative Average Unit Costs of Energy, March 26, 2026 (Federal Register doc. 2026-05899).
What the gap costs, appliance by appliance
Below is the sticker's own sum, run twice. The left column is what the label prints. The right is the same filed energy figure at the electricity price where you live. Nothing else changes between them.
| Appliance | Sticker says | At the US average | Difference |
|---|---|---|---|
| Water Heaters510 models | $157 | $203 | +$45 |
| Room Air Conditioners496 models | $83 | $107 | +$24 |
| Refrigerators8,708 models | $50 | $64 | +$14 |
| Freezers1,709 models | $46 | $59 | +$13 |
| Dishwashers1,076 models | $33 | $43 | +$10 |
| Clothes Washers355 models | $17 | $22 | +$5 |
| All 6 together | $386 | $497 | +$111 |
Both columns price the same filed kWh figure. The sticker column uses 14¢ per kWh, the rate Appendix K1 requires; the other uses the national average residential rate from the EIA.
Only six of the categories on this site carry a label at all. The FTC's rule gives no label content for clothes dryers, and coolers do not appear in it, so there is no sticker figure to compare them against.
Where the sticker is honest
The label is not wrong everywhere, and a page that said so would be making the same mistake it is complaining about. 3 states pay meaningfully less than 14¢, where the sticker overstates what an appliance costs to run, and in 15 more the rate is within a cent of it, which is close enough that the printed figure is simply right.
The sticker overstates in Nebraska, Idaho, North Dakota. If you live in one of those, the yellow label is doing you a quiet favour.
At the other end, Hawaii pays 43.7¢ per kWh — 212% above the sticker's rate. The same refrigerator carries the same yellow number in both places.
Rates are the U.S. Energy Information Administration's average residential revenue per kilowatt-hour, 12-month average through July 2026.
What the sticker still gets right
The comparison still works, and that was always its main job. Two refrigerators sitting side by side are both costed at 14¢, so the one with the lower yellow number really is the cheaper one to run — by the ratio the label shows, whatever you pay per kilowatt-hour. A stale price cancels out of a comparison; it does not cancel out of a total.
The kilowatt-hour figure above the dollars is also current and is not affected by any of this. It comes from the federal test procedure for that product, which is the same measurement this site uses. When the two disagree about money, they are not disagreeing about the appliance.
So: trust the sticker to rank two machines. Do not trust its total unless you are in one of the 15 states where 14¢ is within a cent of what you pay, or one of the 3 where it is more than you pay and the label is being pessimistic on your behalf.
Where these numbers come from
The rate on every EnergyGuide label is set by 16 CFR Part 305, Appendix K1, not by the manufacturer — it is 14¢ per kWh, from Department of Energy figures for 2022. We hold that rule's figure, the Department of Energy's newer one, and the EIA's actual state rates, which is what makes the three comparable on one page.
Costs are that energy use multiplied by a state's average residential electricity price from the U.S. Energy Information Administration. Change the state above and every figure on this page moves with it. Full methodology.