Energy supplier savings claims like 'up to 20 percent off' are typically based on best-case customer usage at the prior peak utility default. Average customer savings is much lower. Four common disclaimer phrases: 'up to' (best case), 'average' (typical case), 'potential' (modelled), 'estimated' (calculated, never guaranteed). All four mean different things. FTC rules require disclaimers to be readable and proximate to the savings claim.
The 4 disclaimer phrases
'Up to X percent': best-case savings under specific conditions. Often unachievable for most customers. Average customer experiences 30 to 50 percent of the 'up to' value.
'Average X percent': typical savings across the customer base. More realistic; still varies by individual usage profile.
'Potential X percent': modelled savings under modelling assumptions. Footnote will detail the assumptions.
'Estimated X percent': calculated using specific inputs. Never guaranteed. Most accurate when paired with your actual usage.
FTC rules on savings claims
Disclaimer must be readable and proximate to the savings claim. Fine-print disclaimers many lines away from the claim violate FTC rules.
Substantiation: the supplier must be able to substantiate the savings claim with data. The FTC can investigate unsubstantiated claims.
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