The Document You've Probably Never Read

Somewhere between signing up for a Texas electricity plan and staring at your first bill wondering where that number came from, there's a document you almost certainly skipped. It's called the Electricity Facts Label (or EFL) and every Retail Electric Provider (REP) in Texas is legally required to give you one before you sign up for a plan.

The EFL is the single most important document in Texas electricity shopping. The Public Utility Commission of Texas (PUCT) designed it to be a standardized disclosure that makes comparing plans straightforward. And in theory, it does exactly that. In practice, most people either never read their Electricity Facts Label or, when they do, walk away more confused than when they started.

That confusion has real consequences. The "rate" you see advertised on a comparison site and the cost you actually pay each month can be wildly different, sometimes by $30 to $50 or more. The EFL is where the truth about your plan lives. But it's also where that truth gets buried under structure that, while well-intentioned, ends up obscuring the information you actually need.

This guide will walk you through every section of the EFL, explain what it means, and more importantly, show you what it leaves out.

What Is an Electricity Facts Label?

An Electricity Facts Label (EFL) is a standardized disclosure document required by the Public Utility Commission of Texas (specifically, §25.475 of the PUCT's Substantive Rules) for every retail electricity plan sold in the state. It's a structured, one-to-two-page document that includes a pricing table showing the plan's average all-in cost per kilowatt-hour at three usage levels — 500, 1,000, and 2,000 kWh — plus a detailed disclosure chart covering the plan type, contract term, termination fees, price change rules, other fees, pre-pay status, and renewable energy content. Think of it as a nutrition label for your electricity plan.

That analogy is useful because it captures both the intent and the limitation. A nutrition label tells you what's in a box of cereal per serving — but it can't tell you whether that cereal is right for your specific diet, at your specific portion sizes, given your specific health goals. The EFL works the same way. It gives you a standardized snapshot, but it can't tell you what your specific bill will look like.

Every REP operating in Texas must produce an EFL for every plan they offer. They're standardized by the PUCT so that — at least in theory — you can lay two EFLs side by side and compare apples to apples. The document is typically one to two pages and covers the same core sections across every plan, which makes it learnable once you know what you're looking at.

What Does Each Section of the EFL Mean?

Every EFL follows a standardized format defined by the PUCT. When you open one, you'll see the same structure regardless of the REP or plan: a header identifying the product, a pricing table, a disclosure chart in a question-and-answer format, and a footer with contact details and a version number. Let's walk through each section in the order you'll encounter it.

The Header

At the top of every EFL, you'll find four things: the REP's name, the product name, the service area, and the date the EFL was issued. This may seem like administrative boilerplate, but it matters more than you'd think. The service area tells you which Transmission and Distribution Service Provider (TDSP) territory — Oncor, CenterPoint, AEP, or Texas New Mexico Power — the plan's pricing applies to. Since TDSP delivery charges vary by territory, the same REP can offer the same plan at different effective rates depending on where you live. And the date tells you when the pricing snapshot was taken — important because delivery charges and regulatory fees can change over time, even on a "fixed-rate" plan.

The Electricity Price Table

This is the centerpiece of every EFL: a table showing the average price per kWh at three usage levels — 500, 1,000, and 2,000 kWh per month. Each figure represents what your all-in cost per kWh would be if you used exactly that amount of electricity. These prices are rounded to the nearest tenth of a cent and include all recurring charges — the REP's energy charge, TDSP delivery charges, and any base fees or credits — everything except state and local sales taxes and reimbursement for the state miscellaneous gross receipts tax.

The 1,000 kWh figure is the one that gets the most attention. It's the number comparison sites display. It's the number REPs advertise. It's the number that Power to Choose uses for default sorting. For the average Texas household, 1,000 kWh is a reasonable approximation of monthly usage — which is why the PUCT chose it as the middle benchmark.

But here's the critical nuance: the rates at 500 and 2,000 kWh can often be significantly different from the 1,000 kWh rate on the same plan. Sometimes dramatically so. The three numbers in this table aren't just different amounts of the same rate — they can reflect fundamentally different pricing structures once you account for base charges, bill credits, and tiered energy rates.

The average price figures already include TDSP delivery charges, which is helpful for total-cost comparison. But the EFL doesn't break out how much of your rate is the REP's energy charge versus the TDSP's delivery charge. We'll come back to why that matters.

The Disclosure Chart

Below the pricing table, every EFL includes a disclosure chart — a structured set of questions and answers that lay out the key terms of the plan in plain language. This is where the EFL gets specific about what you're actually signing up for. Here's what each row covers.

Type of Product. The chart declares whether the plan is a fixed rate product or a variable price product. A fixed-rate plan locks your energy charge for the term of the contract (typically 6 to 36 months). A variable-rate plan can change month to month with no long-term contract obligation.

Contract Term. Stated in months — this is how long your agreement lasts. Month-to-month contracts are 31 days or less. Term contracts exceed 31 days and typically range from 6 to 36 months. The longer the term, the more pricing certainty you get, but the harder it may be to exit early without a fee.

Do I Have a Termination Fee? The chart answers whether you'll be charged for ending your contract early, and if so, how much. Early termination fees typically run $150 to $300 for breaking a fixed-rate contract before it expires. Month-to-month contracts, by regulation, cannot carry a termination fee or penalty. Worth noting: if you're moving to a new address, you generally can't be charged an early termination fee as long as you provide evidence of the relocation.

Can My Price Change During the Contract Period? For fixed-rate plans, the answer is typically "no" — with an important caveat. The REP's energy charge stays locked, but the price may still vary from the disclosed amount to reflect actual changes in TDSP delivery charges, ERCOT administrative fees, or new government-imposed fees that are beyond the REP's control. So while the EFL may say your price won't change, the regulation allows pass-through adjustments on components the REP doesn't set. For variable-rate plans, the answer is "yes," and the next row explains how.

If My Price Can Change, How Will It Change, and By How Much? This is where variable-rate plans spell out the mechanism. Some variable plans change at the REP's sole discretion with no cap. Others are indexed to the previous month's price and can only increase by a defined percentage. The PUCT requires specific disclosure language here depending on the type of variable product, including mandatory bold-print notices about price volatility. For residential variable-rate plans, the EFL must also direct you to the REP's website and toll-free number where you can review the product's price history — a requirement designed to prevent REPs from disguising a volatile pricing track record by simply renaming a product.

What Other Fees May I Be Charged? This row lists any additional fees beyond the per-kWh energy rate — or points you to the Terms of Service for the full listing. Common fees include minimum usage fees (charged if your consumption falls below a threshold) and base charges (a flat monthly fee regardless of how much electricity you use). These fees directly affect your effective rate, especially if you're a low-usage household. A plan with a rock-bottom energy charge but a $9.95 monthly base fee could cost you more than a plan with a slightly higher energy charge and no base fee — depending on your usage.

Is This a Pre-Pay or Pay in Advance Product? A simple yes or no. Pre-pay plans require you to pay for electricity before you use it, rather than receiving a bill after the fact. They work differently from standard plans in terms of billing, disconnection rules, and deposit requirements, and come with their own separate disclosure document (a Prepaid Disclosure Statement) if applicable.

Does the REP Purchase Excess Distributed Renewable Generation? Another yes or no. This tells you whether the REP buys surplus electricity from customers who have rooftop solar or other distributed generation systems. It's a niche detail, but relevant if you have solar panels and want a REP that will credit you for excess power you feed back to the grid.

Renewable Content. The EFL discloses what percentage of the plan's energy comes from renewable sources, alongside the statewide average for renewable content. Texas is one of the nation's largest wind energy producers, so many plans carry a meaningful renewable percentage. Some plans are marketed as "100% renewable," meaning the REP purchases enough renewable energy credits (RECs) to match your usage — though the actual electrons flowing to your home come from the shared grid regardless. Showing the statewide average right next to the plan's percentage gives you an instant benchmark: is this plan above or below the Texas norm?

Contact Information and Version Number

At the bottom of the EFL, you'll find the REP's certified name, business name (if different), mailing address, email, website, PUCT certification number, and a toll-free phone number with hours of operation. This is where you go if you need to reach your REP directly.

Every EFL is also assigned a version number. REPs are required to give each version of their EFL an identification number and publish it on the document. If a plan's terms change, the REP issues a new EFL with a new version number. This matters for record-keeping — if you ever need to dispute a charge or verify what you were promised when you enrolled, the EFL version number on file at that time is the one that governs your contract terms.

What Is the EFL Hiding in Plain Sight?

The EFL was a genuine consumer protection achievement when the PUCT introduced it. But the market has evolved around it. REPs now design plans to look their best at the EFL's specific measurement points. Here are three things the EFL's structure obscures.

The 1,000 kWh Rate Is a Marketing Number

Most comparison shopping — on Power to Choose, on third-party sites, even in casual conversation — revolves around the rate at 1,000 kWh. But your actual usage probably isn't exactly 1,000 kWh. Maybe you're in an apartment using 750 kWh. Maybe you're in a four-bedroom house pulling 1,600 kWh in July.

For a straightforward fixed-rate plan, the difference might be modest. But for plans with bill credits — where you receive a $50 to $150 credit if your usage falls within a specific range — the cliff can be dramatic.

Consider a plan that offers a $150 bill credit if you use between 1,000 and 2,000 kWh. At exactly 1,000 kWh, you get the credit and your effective rate looks fantastic. At 999 kWh, you miss the credit entirely, and your effective rate jumps by 15 cents per kWh. The EFL shows you the rate *with* the credit baked in at 1,000 kWh, but it can't show you what happens at 999 or 1,001.

TDSP Charges Are Baked In but Not Broken Out

As we covered in the pricing table section above, the EFL's average price includes delivery charges from your TDSP. That's useful for total-cost comparison, but it also means you can't see how much of your rate is the REP's energy charge versus the utility's delivery charge — and that lack of transparency creates two real problems.

First, TDSP delivery charges vary by territory. A plan served by Oncor will have different delivery costs than the same REP's plan served by CenterPoint. If you're comparing plans across utility territories — say, you're moving from Dallas (Oncor) to Houston (CenterPoint) — the EFL rates aren't directly comparable even though they look identical in format.

Second, TDSP charges can change even on a "fixed-rate" plan. Remember the disclosure chart's caveat about pass-through adjustments? This is where it bites. Your REP's energy charge stays locked, but the utility's delivery portion can be adjusted by regulators at any time. The EFL captures a snapshot in time, not a forecast.

"Fixed Rate" Doesn't Mean "Fixed Bill"

This trips up a lot of people. The disclosure chart says "fixed rate" for the product type, and "no" for whether the price can change during the contract. That sounds like your bill is locked in. It isn't.

When the EFL says "fixed rate," it means your per-kWh energy charge from the REP won't change for the duration of your contract. It does not mean your monthly bill will be the same every month. Your bill fluctuates because your usage fluctuates — higher in summer when the AC runs, lower in spring and fall. And as we've discussed, the TDSP's delivery charges and other pass-through costs can change independently of your REP contract. The EFL shows you a rate at a specific usage level on a specific date. It's a useful data point, but it's not a prediction of what you'll pay in August.

How Does Watt Owl Read EFLs Differently?

At Watt Owl, we don't just glance at the three EFL rates and call it a day. We analyze EFLs programmatically — extracting the full tariff structure behind each plan, not just the three snapshot numbers the PUCT requires.

That means we can calculate your estimated cost at your actual usage level. Not 500, not 1,000, not 2,000 — yours. If you use 850 kWh in March and 1,400 kWh in July, we can model what each plan costs you at those specific levels and show you where the bill credit cliffs, tiered rates, and base charges actually hit.

We also separate the REP's energy charges from the TDSP's delivery charges. This lets you see what you're actually paying the REP for versus what's a pass-through delivery cost you'd pay regardless of which provider you choose. It's the difference between comparing the whole sandwich and comparing just the ingredients the chef controls.

And we account for the plan structures that the EFL summary flattens: tiered rates that change at different consumption thresholds, time-of-use pricing that varies by the time of day, and bill credits that create dramatic cost cliffs at specific usage levels.

To put it simply: the EFL gives you three data points. We give you the full curve.

This matters because the Texas electricity market has over 140 REPs offering hundreds of plans at any given time. Manually parsing the EFL for each one — and then doing the math at your actual usage level — is theoretically possible but practically unrealistic. That's the gap we fill. You tell us your ZIP code and your usage and we show you what each plan actually costs you, not what it costs a hypothetical household using exactly 1,000 kWh.

Compare plans at your actual usage

How Should You Use the EFL When Shopping for Electricity?

The EFL isn't useless — far from it. It's a valuable starting point. Here's how to get the most out of it.

Start with your actual usage. Before you compare any plans, log into SmartMeterTexas.com and pull your real consumption data for the past 12 months. Find your average monthly usage. Then look at the EFL rate at the tier closest to that average — and pay attention to whether you're near the boundary between tiers.

Read the disclosure chart before the price table. Early termination fees, base charges, and minimum usage fees can transform an apparently cheap plan into an expensive one. A plan with no base charge and a moderate energy rate will often beat a plan with a low energy rate and a $9.95 monthly fee — unless you're a high-usage household.

Check for bill credits. If the rate at 1,000 kWh looks suspiciously good compared to the rates at 500 and 2,000 kWh, there's probably a bill credit involved. Ask yourself: does my usage consistently fall in the credit range? If you're not confident the answer is yes every single month, factor in what the plan costs without the credit.

Compare within your TDSP territory. Since delivery charges vary by utility, compare plans that serve the same territory. Comparing an Oncor plan's EFL rate to a CenterPoint plan's EFL rate is like comparing grocery prices in two different cities — the number alone doesn't tell the whole story.

Don't ignore auto-renewal terms. If you're signing a 12-month fixed-rate contract, check what happens at month 13. Many plans default to a variable rate that can be double or triple your locked-in price. The EFL's disclosure chart will note this, but it's easy to overlook. Set a calendar reminder 30 days before your contract expires.

When in doubt, go deeper. The EFL gives you a useful but incomplete picture. Use a calculator that models your specific usage pattern, not just the three PUCT-mandated snapshots. That's what Watt Owl was built to do.

The Bottom Line

The Electricity Facts Label was a real win for Texas consumers when the PUCT introduced it. It brought standardized disclosure to a market that badly needed it, and it remains the foundation of informed electricity shopping in the state.

But the market has gotten more complex since then. REPs have learned to engineer plans that shine at the EFL's three measurement points — 500, 1,000, and 2,000 kWh — while the real cost picture at your actual usage level stays hidden in the fine print. Reading the EFL is necessary. It's just not sufficient.

Understanding what the EFL shows you — and what it doesn't — is the first step toward making a genuinely informed decision about your electricity plan. The second step is using tools that fill in the gaps the EFL leaves behind.