FTC's Confusing Attempt To Comply With The E-Warranty Act

The Magnuson-Moss Warranty Act of 1975 imposes specific obligations on suppliers (in practice, almost always manufacturers) who provide written warranties on consumer products.¹ The act's purpose was to improve the adequacy of warranty information available to consumers, prevent deception and improve competition in the marketing of consumer products. The act sought to accomplish this by prescribing the types of information that is to appear in the warranty document, requiring that warranties be designated as either "full" or "limited," requiring retailers, with the necessary assistance of the warranty issuers, to make warranty terms available for inspection by consumers prior to purchase and prohibiting certain warranty-related practices.² The act was to be implemented through Federal Trade Commission rulemaking and the Interpretations, Rules and Guides (hereinafter the "rules") that the FTC promulgated are found at 16 CFR Parts 700-703.³