In2aqua Faucets Review & Rating Updated: June 4, 2024 Our panel of consu­mers and industry professionals has rec­ognized In2a­qua fau­cets as a Best Val­ue in luxury fau­cets made or assembled in Eur­ope. Read the Best Fau­­cet Val­ue Re­port for more in­for­ma­tion.

Imported

Germany

In2aqua GmbH
Koenigstraße 26
70173 Stuttgart
Germany
(800) 257-6051

U.S. Distributor:
Decorative Plumbing Distributors
4200 Business Center Dr.
Fremont, CA 94538-6356
customer.service@dpdonline.com

Rating

Business Type

Product Range

Kitchen, Bath, Prep, and Bar Faucets

Certifications

Download In2aqua certificates.

Brands

In2aqua

Street Price

$340 - $1,100

EPA Wa­tersen­Se® Part­ner­ship is limited to companies that manufacture, assemble, or import wa­ter-sav­ing products that are certified to meet strict WaterSense® standards.

Warranty Score

Cartridge

lifetime¹
(1-year labor)²

Finishes

Lifetime
(1-year labor)

Mechanical Parts

Lifetime
(1-year labor)

Proof of Purchase

Required

Registration

Required

Transferable

No

Meets U.S. Warranty
Law Requirements

Yes

Warranty Footnotes:

1. For as long as the original purchaser owns the faucet provided it is purchased from an authorized showroom and is registered with In1aqua. Otherwise, two years.

2. "[F]or the FIRST YEAR of ownership ONLY, provide,in addition to parts, THE SERVICE LABOR in your home needed to repair the product"

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Download the In2aqua warranty.

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Learn more about faucet warranties.

This Company In Brief

In2aqua is a German company founded by industry veteran Chris Marshall to manufacture high-quality luxury fau­cets in the Nor­dic-Hans­e­a­tic-Ger­man styling tradition characteristic of such companies as

It assembles faucets in Germany using critical components from European sources, including a proprietary mixing cartridge that is one of the best available.

Styles are limited but expanding and encompass all three design families: traditional, transitional, and contemporary.

In2aqua equips its single-handle faucets with a super cartridge that the company calls the PVD+. The ceramic discs in the cartridges are coated with diamond-like carbon, one of the hardest materials known to man. It may be one of the first true lifetime cartridges.

The company supports its faucet with what is perhaps the strongest limited lifetime warranty in North America. It includes one year of a plumber's services to repair or replace a defective In2aqua fau­cet in your home.

It is the first fau­cet warranty to pay for plumbing labor, often the most expensive part of repairing or replacing a defective fau­cet. Mostl other faucet warranties specifically exclude the labor required to repair or replace a defective fau­cet.

Hansa Armaturen GmbH was a German company that made excellent faucets sold mostly in Europe. It was virtually unknown on this side of the Atlantic. So, in 2013 when Hansa was sold to Finland's Oras Group, the event was barely noticed in North America.

The only part of the transaction that caused a minor blip on American financial radars was the simultaneous sale of Hansa's Swiss subsidiary,

In the same series of transactions, Hansa lost Christopher Marshall, its CEO.

Marshall almost immediately formed his own fau­cet company, taking with him decades of management and marketing experience in European fau­cet manufacturing with Hansa,

The new company, In2aqua enjoyed an immediate success in its home country, Germany, and began selling to the North American market on a limited basis in 2014.

The Company

In2aqua GmbH is organized as a Gesellschaft mit beschränkter Haftung which is roughly equivalent to the American limited liability company (LLC).

It is the organizational form traditionally used by small businesses in Germany, combining adequate protection from personal liability with flexibility in organization and operation with relatively few filing and reporting requirements.

Despite its traditional form, however, In2aqua is anything but a traditional company. Its business model is one rarely seen and even more rarely successful in the faucet industry. In2aqua, however, has managed to make it work.

It sells faucets in the U.S. and Canada from its headquarters in Stuttgart, Germany without having established a North American subsidiary. It operates through a logistics company in California that handles all order fulfillment, warehousing, and replacement parts.

In2aqua has grown dramatically on this side of the Atlantic since its introduction in 2014 – from barely a dozen showrooms to over 200 retail outlets years later. (To locate an authorized in2aqua showroom or other retailer, visit the showroom directory on the company website.)

The company has recently opened a new plant in Holzgerlingen, Germany dedicated solely to producing products to meet the needs of its rapidly growing North American market.

Customer service is handled from the U.S. but technical support is through English-speaking specialists located in Germany.

It is an innovative and seemingly well-con­sid­ered plan to sell high-quality fau­cets using a low-overhead business model that helps keep In2aqua prices down.

The strategy takes full advantage of the fact that with modern communications, especially smartphones, and the internet, physical proximity to a particular market is no longer necessary.

To a plumber or homeowner located in Miami, Memphis, or Montreal, technical or customer support provided from Europe is just as useful as help from California or Georgia. It no longer makes much difference where support comes from so long as both parties speak the same language.

The In2aqua Website

The In2aqua website is crisp, visual, striking, intuitive, and very simple to navigate. It is a responsive design that displays properly on any size device from smartphone to full-size desktop monitor.

Navigation is menu-driven. The main menu is hidden, however, until the user clicks on the icon at the top right on the home page.

The site search function is very efficient so long as the searches are limited to product features. In our standard tests, it easily handled searches on finishes such as "matte black" (useful for finding all of the products available in a particular finish) and on faucet characteristics such as all "widespread" bathroom sink faucets.

It did not work for non-product searches such as "warranty" or "certifications."

Most listings display a 3/4 view of the faucet. A second image showing the faucet with dimensions is available in most listings at a click of the mouse. These images can be zoomed and downloaded.

A 360° icon opens an image of the faucet that can be rotated using the mouse to view the fau­cet from any angle.

The feature takes the guesswork out of selecting a fau­cet from one or two static images. No more imagining what the back of the fau­cet looks like, just rotate it with the mouse until the back is revealed.

It is also used on the websites of a few other companies including , and is the most effective means we have seen of helping potential buyers fully visualize a fau­cet.

Three bars display detailed information about the faucet.

•  Product Features & Benefits  Dis­plays a drop-down list of features, some of which are specifications.
•  Technical Information and Warranty  Lists four .pdf documents that can be downloaded and displayed:
  1. Links to the In2aqua warranty.
  2. Lists the Features and Benefits of the faucet and displays a dimensioned image.
  3. Displays an exploded parts diagram that identifies and labels each part of the faucet. Unfortunately, the labels are in German and not especially helpful to English-speakers.
  4. Displays the installation instructions for the faucet.
•  Applicable Code and Listing Information  displays a drop-down list of codes, standards, and regulations with which the faucet complies.

A few necessary specifications are missing. These are identified in the Min­imum Fau­cet List­ing In­for­ma­tion table elsewhere on this page. These omissions are minor, however.

The company scores a solid B+ for providing almost all of the essential information needed for an informed faucet-buying decision – the highest score we have yet recorded.

Overall the information provided on the website is a model for other faucet companies to follow.

3d Models: For designers, architects, and other specifiers, .dxf-format fau­cet models make incorporating the faucets in computer-aided designs very simple but, be aware that the models are dimensioned in metric, not U.S. conventional units, and will require translation.

In2aqua Faucet Design

In2aqua groups its faucets in collections that include faucets, showers, tub fillers, and matching accessories for a well-coordinated look.

• The Classic, Lana and Lana X collections are traditional with classic lines and detailing that evokes a sense of the past without appearing outmoded or trite.

• The Edge, Riva, and Riva X collections are contemporary with crisp, sleek, and functional styling that approaches but does not quite reach, the severe austerity of industrial design.

• The Style, Strata, and Strata X collections are transitional, falling between classic and contemporary, featuring updated straightforward lines that are neither as ornate as traditional nor as severe as contemporary designs.

The original collections: Classic, Edge, and Style include kitchen faucets. The newer Lana, Lana X, Riva, Riva X, Strata and Strata X collections do not, although reportedly they are coming soon.

All faucets feature the distinctive and well-defined Nor­dic-Hans­e­a­tic styling that is characteristic of many North Eur­o­pe­an companies such as

Much of the design and prototyping is handled by Werksdesign, an industrial design studio based in Berlin that is a frequent winner of European design awards for its crisp product styling.

Faucet Construction

These are the traditional, heavy-weight, cast and machined, hand-polished, low-lead brass^[1] and alloy products made pretty much the same way that the best faucets have been made for most of two hundred years while incorporating the latest technological advances for fault-free operation over the life of the fau­cet.

According to the company's founder and CEO, Chris Marshall, In2aqua intends the faucets to be a lifetime investment and the last sink faucet you will ever need to buy.

For parts of the fau­cet not under water pressure such as handles, baseplates, and , the In2aqua uses , a zinc/aluminum alloy commonly used by nearly all faucet manufacturers to fashion these ancillary parts.

ZAMAK saves a few dollars in manufacturing costs and does not affect the overall quality of the fau­cets.

Faucet Valve Cartridges

The company cuts no corners in either component selection or manufacturing.

Components that are commonly plastic in other fau­cet lines are brass in In2aqua fau­cets.

The M-Lock^™ Collar

Even the never-seen locking collar that holds the In2aqua fau­cet's valve cartridge in place is brass.

Most other fau­cet companies – even those that sell upscale products – have switched to plastic for this critical component.

Plastic, however, can flex, allowing the cartridge to deform. De­for­ma­tion is a common cause of leaks in ceramic cartridges. In2aqua's proprietary, all-brass M-Lock^™ collar all but eliminates that particular problem.

Lubricant-Free Discs

The second component of In2aqua's robust cartridge technology are the cartridges themselves.

Most ceramic cartridges require a durable lubricant to help the ceramic discs slide over each other smoothly for easy operation.

The lubricant is the Achilles heel of ceramic cartridges. Even though it is not soluble in water, it is not permanent.

It will inevitably be eroded away by the mechanical abrasion of the stream of water (and dissolved minerals) passing through the cartridge day after day, eventually resulting in a fau­cet that is more difficult to operate. In extreme cases, it may even seize up, failing altogether.

The ceramic cartridges used in In2aqua faucets are designed and manufactured to operate smoothly without a lubricant.

Flühs Stem Cartridges

The company's two-handle faucets are fitted with lubricant-free stem cartridges manufactured by Flühs Drehtechnik, GmbH in Lüd­en­scheid, Ger­many, considered by most in the fau­cet business to be one of the best, if not the best, European fau­cet cartridge made for two-handle faucets.

Kerox Mixing Cartridges

Single-handle faucets include a proprietary ceramic mixing cartridge manufactured by the Hungarian firm, Kerox Kft, that incorporates a disc technology the company calls PVD+^™.

The discs are given a coating of a material called diamond-like carbon (DLC) applied using a process called (PVD), that coats the ceramic discs with a very thin layer of DLC material.

DLC not only improves a ceramic disc's hardness but creates an exceptionally "slippery" surface that moves freely without the need for a lubricant.

Resistance to Mineral Build-up

Perhaps more importantly, however, minerals in tap water have a hard time sticking to the slick DLC surface.

Mineral or lime-scale build up is the cause of most ceramic cartridge failures.

Ceramic discs themselves, even regular uncoated ceramic discs, are virtually indestrucable. In min­er­al-free water "soft" water they will last nearly forever.

But, only 20% of Americans live in places where the water is relatively mineral free. For the rest of us, the minerals in "hard" water accumulate slowly but inexorably on uncoated ceramic discs.

After a while they impare the ability of the discs to close completely, which results in a leak. It may take years, but it will happen eventually.

Out experiments with DLC coatings showed that minerals simply don't stick. In fact, nothing sticks, and we tried every sticky subbstance we could think of, up to and including super glue.

Cartridge Test Results

In2aqua estimates that the lu­bri­cant-free PVD+ discs will last ten times longer than uncoated discs.

Based on the results of independent laboratory tests, however, that estimate may be more than a little conservative. After putting PVD+ cartridges through four million consecutive off/on-hot/cold cycles over 90 days, the discs showed no visible wear.

Four million cycles are equivalent to about 560 years of use in an average home kitchen.

We think the odds are overwhelming that PVD+ discs will operate for the entire lifetime of an In2aqua fau­cet without replacement.

Life-Cycle Cartridge Testing: For a video showing the operation of the machine that puts faucets through life-cycle testing, go here.

Faucet Aerators

Neoperl^® supplies most of the used in in2aqua faucets. Faucets with pull-down sprays are equipped with aerators from Amfag S.r.l., a company manufacturing in Casaloldo, Italy. Amfag is Neoperl's competition in Europe. Both products are at about the same level of quality and endurance.

Fau­cet aerators used to be simple devices, often no more than a few layers of window screen, that merely infused a little air to soften the water stream so it would not splash out of the sink.

Today, however, they are precision products used to limit water volume to the lower flows required by federal and state water conservation laws, and in faucets with pull-out sprays, to prevent back-flow that could contaminate household drinking water.

It is important to long-term faucet functionality that these be the best available, and with Neoperl and Amfag, In2aqua has two of the best.

Kitchen Faucet Spray Heads

In2aqua has always equipped its pull-down kitchen faucets with brass spray heads (the industry term is "wands"). For its pull-out sprays, In2aqua turned to plastic spray heads after receiving complaints from its European customers that the larger pull-out wands were too heavy to handle comfortably.

The company receives few complaints about the plastic sprays, and our very limited experience with the component in a single test faucet was favorable.

In general, however, plastic wands experience more failures than metal wands for reasons not fully understood, and while engineers have made vast improvements in the component over the past decade, the problems have not entirely diappeared.

In consequence, the company has decided to return to brass wands for its pull-out faucets, but in a different construction that reduces weight. The conversion, however, is not yet done. Current pull-out wands may still be plastic.

Water-Saving Design

In2aqua faucets have been engineered from the bottom-up to be water-saving low-flow devices intended to comply with even the most restrictive maximum flow limits, including the new 1.2 gallon-per-minute (GPM) maximum flow now required in California bathrooms (See more below).

Faucets designed for a higher flow rate such as the U.S. maximum of 2.2 GPM, can be restricted to a lower flow by simply reducing the size of the aperture built into the aerator but the result is often a weakened, feeble stream of water that is not very satisfactory.

By engineering the faucets to be low-flow, this problem has been largely eliminated in In2aqua faucets.

In2aqua Faucet Finishes

In2aqua faucets are available in 5 finishes.

The first In2aqua finishes were Polished Chrome and Satin Nickel on bathroom sink faucets and Polished Chrome and Stainless Steel on kitchen faucets.

These have now been supplemented by Matte Black. One faucet, a two-handle pull-down faucet from the Edge collection is available in a Matte Black/Gold .

Electroplating

Polished Chrome is an finish of the type used to protect faucets for most of a century.

The process involves immersing the fau­cet and the metal to be used as plating in an acid bath, then applying an electrical charge to both objects so metallic ions are drawn from the plating metal to the fau­cet.

In2aqua's Chrome is a multi-layer coating. One or more undercoats are applied, then two or more coats of chrome.

Chrome, a relatively hard metal, can be polished to a high shine. It resists damage from ordinary handling but can be scratched by abrasive cleaners, so keep Brillo^® and Scotch Brite^® far away from the faucet.

Physical Vapor Deposition

Gold, Stainless Steel, and Satin Nickel finishes are (PVD) coatings.

Physical vapor deposition is one of the latest space-age fau­cet finishing technologies, rapidly replacing electroplating as the finish of choice.

Although the technology was discovered in the 19th century, it did not move from the laboratory to industry until the 1950s when a need arose for a super tough coating for components inside the hellish environment of nuclear reactors.

The process itself is almost out of a Star Wars^® movie.

Load a vacuum chamber with unfinished fau­cet components, remove all the air, and add back a carefully calculated mix of nitrogen or argon and reactive gases.

Add a rod of the metal to be used for the coating material. Heat that rod to a temperature so high that the metal dissolves into its individual atoms.

The atoms mix with the various reactive gases to get the desired color and finish effects and are then deposited in a very thin layer – 2 to 5 microns – on the fau­cets.

Despite being just microns thick, a PVD coating is extremely dense and bonded with the metal of the faucet at a molecular level. In consequence, it is very hard and extremely durable. In standard abrasion tests, PVD finishes were 10-20 times more mar- and scratch-resistant than electroplated chrome.

In our admittedly less formal tests, a Scotch Brite^® pad mildly scratched a PVD chrome finish, bur it took work. a Brillo^® pad had no effect at all. (Don't try this at home! Keep all scouring pads far, far away from your faucets.)

PVD can usually be maintained with just an occasional wipe from a damp cloth to remove water spots.

Powder Coating

Matte Black is a , a form of dry paint applied as an electrically charged powder, then heated in a kiln to about 400°F to melt, cross-link, harden the powder, and bind it to the faucet.

In2aqua's Unique Go Pro Labor Warranty

The First of its Kind

The In2aqua Go Pro warranty promises not only to deliver the parts to fix a defective In2aqua fau­cet for the lifetime of the buyer but to provide the labor required to fix the fau­cet during the period when a defect is most likely to show itself – the first year of ownership.

The warranty is the first of its kind in North America and the only fau­cet company we know of that will provide plumbing labor free of charge to fix a defective fau­cet.^[3]

To get the Go Pro warranty, however, you have to do some work. First, it is only available on faucets purchased from an authorized dealer (so, no e-Bay purchases). And, you must register the warranty.

Otherwise, you are stuck with the standard Eur­o­pe­an two-year warranty that does not include plumber labor. You do not want that, so be sure to register.

Powder coatings are generally considered only semi-durable compared to metal finishes. However, the process used to produce In2aqua's powder coating, Matte Black, results in a very tough finish covered by the company's lifetime guarantee.

Nonetheless, extra care is needed to keep powder coats looking like new. Carefully follow In2aqua's care and cleaning instructions.

Installation

In2aqua's installation instructions are in "universal" format with lots of illustrations and virtually no text.

Our plumbers had no problem following the installation procedure, which he rated as "easy" on a five-point scale ranging from "very hard" to "very easy".

The Lifetime "Go-Pro" Warranty

Like much of what the company does, In2aqua's "Go Pro" lifetime warranty is different.

What the company calls its "standard warranty" is a two­year Eu­ro­pean-style warranty.

But, if the fau­cet is purchased from an authorized In2aqua retailer and then registered with In2aqua, the warranty is "extended" to the lifetime of the original purchaser as long as he or she

"owns the fau­cet and resides in the dwelling in which the fau­cet is originally installed."^[2]

The lifetime warranty includes labor for the first year of ownership.

Overall industry experience suggests that if a fau­cet is going to fail due to a manufacturing or material defect, the problem will usually show up in its first few months of operation.

If an In2aqua fau­cet fails in the first 12 months, In2aqua will provide not just the parts to fix the fau­cet, but send a licensed plumber if necessary to install the parts.

No other fau­cet company offers plumbing labor as a part of its warranty.^[3]

The warranty is based on our Model Lifetime Limited Residential Faucet Warranty and complies in all respects with warranty laws in the U.S. and Canada, including the Mag­nu­son-Moss War­ranty Act (15 U.S.C. §2308) – the federal law dictates the form and minimum content of consumer product warranties in the U.S.

Customer Service

Customer and warranty service is excellent. Warranty claims are handled with dispatch. More often than not, required repair parts are on their way the same day.

We did not conduct our standard customer service tests. They do not work with small companies. Agents soon realize they are being tested, which distorts the results. We did, however, ask hard questions designed to befuddle all but the most knowledgeable agent. In2aqua's agents proved to be unbefuddable.

The Better Business Bureau has no file on the company which means that in the years the company has been in business in the U.S., the BBB has received no complaints about the company or its products and has had no reason to open a file.

Faucet Manufacturing

In2aqua is not a fau­cet manufacturer. It is an .

It designs its faucets, then assembles and tests them in Bavaria, but other companies manufacture most of the parts and components that go into the faucets.

The German company, Flühs Dreh­tech­nik, GmbH does much of the casting and machining.

A nearly 100-year-old German manufacturer, Flühs, in addition to making excellent ceramic cartridges (See above), is an industrial-scale metal fittings fabricator with a worldwide reputation for incredible accuracy.

Other European firms contribute, including companies in Switzerland, Italy, and Hungary as do manufacturers in Taiwan and China.

Component manufacturing by specialist companies is becoming the usual practice in high-quality fau­cet production.

The thinking is that specialist sub-contractors can do a better job, faster and at less cost because that's all they do.

Most of Europe's best faucets are made this way by companies that still design, engineer, and assemble their faucets but no longer manufacture the parts and components that go into them.

for example, has been out of the casting and machining business for more than a decade.

It still assembles and finishes its faucets in its plant in Iserlohn, Germany but the components used in its faucets are made by a multitude of subcontractors.

Dornbracht considers metalwork to be"low tech" and of little "strategic importance. In its view, the critical parts of the fau­cet building are assembly and final finishing.

Testing and Certification

German fau­cet companies are, as a rule, meticulous about complying with all of the Byzantine matrix of laws and regulations that govern the safety, reliability, and water flow rates of faucets sold in North America.

In2aqua is no exception.

CalGreen^® Certified: In2aqua faucets comply with the energy-saving requirements of the California Green Buliding Standards Code. For a fau­cet to display the CalGreen label, it must have been tested for compliance with CALGreen Chapter 4, Residential Mandatory Measures, Section 4.303 Indoor Water Use and certified by an independent testing organization.

Comparable Faucets

Faucets of similar quality with a lifetime warranty include: However, none of these companies will pay the cost of labor to repair or replace a defective faucet under warranty.

Conclusions

The more we learn about these faucets, the better we like them.

In2aqua did everything right from the very beginning: a strong warranty, exceptional customer service, a well-designed and informative website, but most important of all, very good quality faucets.

The faucets are some of the most intelligently designed and engineered faucets we have examined in years of reviewing faucets and faucet companies.

The components that go into these faucets are among the best available.

Advanced technologies, precision machining, and faultless finishes make this a line of faucets that can actually deliver on the promise of a lifetime product.

We judge In2aqua faucets to be a very good value — more upscale fau­cet for the dollar than is available from other brands of premium European faucets. The fau­cet line is worth a long look if you are in the market for a stunningly finished, reliable, high-end (and high-tech), lifetime product.

The brand has been repeatedly selected by our panel of industry professionals and consumers since 2016 as the Best fau­cet Value in a luxury fau­cet made or assembled in Europe, and was the panel's pick once again in our most recent report.

We are continuing to research the company. If you have experience with In2aqua faucets, good, bad, or indifferent, we would like to hear about it, so please contact us or post a comment below.

1. Common yellow or "alpha" brass is about 63% copper, the rest being zinc and small amounts of other metals such as aluminum (for added strength) and lead (for malleability, which makes it easier to shape and form). Lead content for brass used in drinking-water faucets is limited by law to not more than 0.25% (1/4 of 1 percent) by volume. Brass that meets this standard is considered "lead-free".
2. To retain the malleability needed to form the material without breaking or cracking, lead has been replaced in brass with other materials such as silicon and bismuth. Bismuth is 300 times rarer than lead, even rarer than silver, and much more costly, which is the reason that lead-free brass alloys are considerably more expensive than leaded brass and why savvy fau­cet manufacturers substitute zinc alloys for the components of a fau­cet that do not need the strength of brass.
2. It is unusual for a homeowner to move a fau­cet to a new house in the U.S. or Canada, but more common in much of Europe where many kitchens are designed to be portable and are often moved from house to house — right down to the kitchen sink – and fau­cet.
3. Although Germany was at the forfront of the trend to bespoke or fitted kitchens, building a lot of them in the 1930s, post-war Germany favored to portable kitchen. American military families during the post-war occuplation of German choosing to live "on the economy" rather than in military housing wer oftesn surprised to find that the kitchen in their German house was a bare room with rough-in plumbing indicating where the sink was to be installed. They had to buy a kitchen. Fortunately, even small cities in Germany have many kitchen stores with prices ranging from Ikea to Oh-my-God! The at least 30-day wait for all the parts to arrive and the kitchen installers to show up, meant getting cozy with the local McDonald's! (Luckily, a German Big Mac is still a Big Mac and a Happy Meal is just as Happy. Fries, however, are pommes frites or just pommes. (But, if you want ketchup on those pommes, it's an extra charge – per packet.)
3. The In2aqua warranty provides that

   "For FAUCETS, BIDET FAUCETS and SHOWER VALVES ONLY, for the FIRST YEAR of ownership ONLY, [In2aqua will] provide,in addition to parts, THE SERVICE LABOR in your home needed to repair the product."

4. In2aqua is not the only company to provide a labor warranty, but it is the only one to provide one voluntarily. All the rest are the unintended consequence of some very poor warranty wording that leaves the company liable for the labor required to repair or replace a defective faucet.
5. For example, the upscale seller of faucets in Chicago, intends to offer a "limited" warranty that excludes labor. But, because of incompetent drafting, its warranty as a matter of law is a "full" rather than the intended "limited" warranty. Federal law requires a company providing a full warranty to cover the cost of the labor required to fix a defective product. (16 CFR §700.9)