tort-based, but there is a confusing mix of case law in the United States. In modern English law, sellers often avoid using the term 'represents' in order to avoid claims under the Misrepresentation Act 1967 (although English law will look to the substance rather than the form of the representation to decide what it is), while in America 'warrants and represents' is relatively common. Some modern commentators suggest avoiding the words and substituting 'state' or 'agree', and some model forms do not use the words; however, others disagree. Product types Appliance warranty Canada and United States Written warranties on new major appliances, such as refrigerators, kitchen stoves and dishwashers, usually cover the cost of parts and labor to repair defects in materials or workmanship which appear under normal home use. Warranties often cover defects up to a year after purchase or delivery. However some exclude new owners when a house or appliance is sold within the year (Frigidaire, LG, Samsung). Others do let warranties transfer to new buyers (Amana, General Electric, Whirlpool). Some manufacturers cover refrigerators' sealed parts (compressors, tubing, etc.) for five years (General Electric, Samsung, Whirlpool) or seven years (LG) or ten years (KitchenAid). Warranties on water heaters cover parts for 5 to 12 years in single family residences, one year otherwise. They do not cover new owners when a house or heater is sold; nor do they cover the original owner if the heater is moved to a second location. Tank models from A. O. Smith do not allow heating elements to be replaced with lower (or higher) wattages, and do not cover renter-occupied single family. They end if the unit is flooded or ever uses desalinated or deionized water, such as municipal desalination plants or reverse osmosis filters. Smith's tank models for manufactured housing do not provide coverage if a whirlpool or hot tub is connected. Tank water heater warranties exclude labor, liability for water damage, and shipping cost to return the old heater or parts. Tankless warranties do not exclude water damage; they cover labor for a year, and Ruud/Rheem covers return shipping on tankless models. Smith's tankless water heaters do not restrict coverage to a single family, and require professional installation. Implied warranties under US law could extend for longer periods. However, most states allow the written warranties to include clauses which limit these implied warranties to the same time period as the written