The FTC's R-Value Rule: What Insulation Installers Must Tell Customers

“Do I have to give the customer an R-value sheet?” Yes, if you install home insulation. The Federal Trade Commission’s R-value Rule, 16 CFR Part 460, dates from 1979 and covers installers. It says what you must show a customer before they agree to buy, what your receipt must say after the job, and what your ads and sales talk may and may not claim. Most of what it asks of an installer is paperwork you set up once.

Who it covers

The rule covers members of the home insulation industry, and it names installers in the list, along with manufacturers, distributors, retailers, utilities and advertisers (§460.3). You must follow it each time you sell, install, promote or label home insulation (§460.4).

“Home insulation” is broad (§460.2): any material mainly used to slow heat flow, whether mineral or organic, fibrous, cellular or reflective, rigid, semirigid, flexible or loose-fill, in old or new homes, condominiums, apartments, modular homes and mobile homes. It leaves out pipe insulation and all duct insulation except duct wrap. So the rule can reach beyond insulation companies: a remodeler who puts batts in a wall or an HVAC installer who wraps ducts is installing home insulation as the rule defines it.

The stakes are set out in §460.1: breaking any of the rule’s requirements is an unfair or deceptive act under Section 5 of the FTC Act, and each violation can be fined up to the amount in 16 CFR §1.98. For Section 5(m)(1)(A), which covers rule violations made with actual knowledge or knowledge fairly implied, §1.98 lists $53,088 per violation for penalties assessed after January 17, 2025.

Before the customer agrees: the fact sheet

An installer must have fact sheets for the insulation products it sells and, before customers agree to buy, show them the fact sheet for each type of insulation they want (§460.15). The rule lets you choose how: hand each customer a copy, or keep the sheets in a binder and show it before they agree.

You do not write the fact sheet. Manufacturers must give one to the installers they sell to (§460.13), with the maker’s name and address, a heading naming the type of insulation, the R-value chart, and a boxed statement in 12-point type headed “READ THIS BEFORE YOU BUY.” Greenfiber’s fact sheet for its Sanctuary cellulose is one example: the coverage chart and the “Read this before you buy” statement are both on it. Ask your supplier for the current sheet for every product on your truck.

In practice, attach the fact sheet to every estimate you email, and keep the PDFs on the phone or tablet you quote from. Then the estimate itself gives you a record that the customer had it before agreeing.

After the job: the receipt

You must give the customer a contract or receipt for the insulation you install, dated and signed by the installer (§460.17). What it shows depends on the type:

Four more rules in the same section trip people up:

• Work out the R-value from the data the manufacturer gives you, not from a rule of thumb.
• If you insulate more than one part of the house, give the figures for each part. One receipt is fine, as long as you do not add up the coverage areas or R-values of different parts.
• Never multiply an R-value for one inch by the number of inches installed.
• For blown insulation, the bag count is required, so count the empty bags before they go in the dumpster.

The Department of Energy’s job aids for weatherization installers go one step further: the one for insulating an attic has the crew check depth and density against the manufacturer’s coverage chart, and post an insulation certificate by the attic entrance with the type, coverage area, installed and settled thickness, R-value and number of bags. Stapling a copy of your receipt by the hatch costs nothing and answers the next inspector, buyer or contractor who looks.

Ads, flyers and the price on your website

The rule also governs what you advertise (§460.18):

• An ad that gives an R-value must give the type of insulation and the thickness needed to reach it, plus this statement: “The higher the R-value, the greater the insulating power. Ask your seller for the fact sheet on R-values.”
• An ad that gives a price must give the type of insulation, the R-value at a specific thickness, that statement, and the coverage area for the price. A price per square foot does not need the coverage area.
• An ad that gives a thickness must give the R-value at that thickness, with the statement.
• An ad comparing two types of insulation must compare them over the same coverage area, with the R-value at a specific thickness for each.

These disclosures do not apply to television or radio ads or to “space-constrained” ads, which the rule defines as interactive media, such as search results and banner ads, whose space or format prevents the disclosures from being made clearly and conspicuously. The burden of showing there was not enough room is on you. A page on your own website usually has room, so a price there should carry the type, the R-value at a stated thickness, the statement and, unless the price is per square foot, the coverage area.

The claims the rule limits

Savings claims (§460.19). If you say or imply that insulation will cut fuel bills or fuel use, you need a reasonable basis for the claim, and the ad or material must carry this statement: “Savings vary. Find out why in the seller’s fact sheet on R-values. Higher R-values mean greater insulating power.” A claim about a combination of products must list them and say how much of the saving came from each, or rank them. If you are not the manufacturer, you are liable only if you know or should know the manufacturer has no reasonable basis for the claim. Records of the data behind a savings claim must be kept for at least three years.

R-value per inch (§460.20). Do not give an R-value for one inch or an “R-value per inch” in labels, fact sheets, ads or other promotional materials, unless test results prove the R-value per inch does not drop as the product gets thicker.

Government claims (§460.21). Do not say or imply that a government agency uses, certifies, recommends or favors your product, or that it meets a government standard, unless it is true.

Tax claims (§460.23). Do not say or imply that a product qualifies for a tax benefit unless it is true. This one matters right now. The IRS says the federal Energy Efficient Home Improvement Credit could be claimed for improvements made through December 31, 2025, and that labor for installing building envelope components did not qualify even then. A 2026 sales pitch built on “30% back from the IRS” for new insulation says something the IRS page does not support. If a state or utility program pays a rebate, quote that program’s own terms, not a summary of them.

Other rules still apply

The R-value Rule says the FTC’s three-day cooling-off rule stays in force (§460.24), so a job you sell in the customer’s home may also need the cancellation notice that the 3-day right to cancel explains. The same section says state and local laws inconsistent with the rule are preempted, though a state may petition the FTC to enforce its own. And homeowners can read the rules too: the FTC’s consumer page on buying insulation tells them that installers and retailers must provide fact sheets, and to report problems at ReportFraud.ftc.gov.

How much insulation to recommend, and how to price it from the target R-value and the bag count on the coverage chart, is in Pricing Attic Insulation by R-Value and Square Foot. More for insulation contractors is on our insulation page.

The checklist

• A current manufacturer fact sheet for every product you install, shown or sent before the customer agrees
• A dated, signed receipt with the figures for each part of the house, from the manufacturer’s data
• For blown jobs: coverage area, initial and settled thickness, R-value and bag count
• Ads with an R-value, price or thickness carry the type, the thickness or R-value, and the required statement
• No R-value per inch, no unproven savings, no government or tax claim that is not true
• Savings-claim records kept for three years

General information, not legal or tax advice. Rules change and vary by state; check with the agency named above or a professional for your situation.