Frequently Asked Questions:
State-Regulated Lamps

If clarification is needed on any of the information contained in the FAQ document, please contact the Appliance Efficiency Program via email at: appliances@energy.ca.gov with the following title in the subject line: State-Regulated Lamps FAQ.

See FAQs related to:


General/Other

The U.S. Department of Energy published two Federal Register notices of final rules adopting a definition for general service lamps (82 Fed. Reg. 7276 and 82 Fed. Reg. 7322 (Jan. 19, 2017)). Do these definitions apply to the California Appliance Efficiency Regulations (Title 20)?

Not at this time. All relevant definitions for the California Appliance Efficiency Regulations (Title 20) are found in section 1602 of the regulations. The more expansive definition for general service lamps will take effect either upon a Commission rulemaking to adopt a new definition for general service lamps or the effective date of the federal rules, whichever is sooner.

What are the key changes or takeaways for integrated LED luminaires?

An LED luminaire which connects directly to a branch circuit is not regulated by California’s Appliance Efficiency Regulations (Title 20, California Code of Regulations, sections 1601-1609). A portable luminaire that connects to a branch circuit with a plug and cord is regulated by Title 20 as a “portable luminaire” and must be certified to the Commission’s database. An LED downlight retrofit kit with an E12, E17, E26, or GU24 connector base is regulated by Title 20 as a “state-regulated LED lamp.” The Building Efficiency Standards (Title 24, Part 6) have separate, additional requirements for certain luminaires that may require certification to the Commission’s database for installation in new residential construction.

Are flexible LED strips regulated under any of Title 20?

Generally, flexible LED strips are not regulated by Title 20. However, if the LED strips connect to a branch circuit with a plug and cord connection, they may be portable luminaires, which are regulated under Title 20. LED strips installed in new residential construction must meet certain requirements under Title 24, Part 6.

Are compact fluorescent lamps (CFL) bulbs lawful for sale under Title 20?

Yes, as long as they meet the state-regulated general service lamp regulation, Title 20, section 1605.3(k) Table K-12 (i.e., 45 lumens per watt, minimum rated lifetime of 1,000 hours). In addition, CFLs must have a minimum CRI of 80 under federal law.

If a CFL is allowed with portable luminaires, and the requirements for LED bulbs are increasing drastically, won't that push luminaire manufacturers to not adopt LED and stick with an older, less efficient CFL?

The manufacturer of a portable luminaire has always had multiple compliance path options, including both CFL and LED. The ability for the manufacturer to choose a compliance path has not changed.

Can I compare an LED lamp to an incandescent lamp (e.g., state “incandescent replacement” or similar on the packaging) when the LED lamp has a correlated color temperature (CCT) higher than 3000K? What if the LED lamp is non-dimmable?

No to both questions. A claim of incandescent equivalency means the lamp must meet all three qualifications that are perceived by consumers as being the functional equivalent of an incandescent lamp: warm CCT, fully dimmable, and a certain level of brightness (lumen output). See Title 20 section 1607(d)(13)(B). Making a claim of incandescent wattage equivalencies has separate, independent requirements. See the first question under Standard in this FAQ.


Certification and Effective Dates

If an LED lamp is certified to the Commission’s database (MAEDBS) for Title 24 “high efficacy” lamp requirements, does it need to be certified again for the Title 20 requirements?

Yes, if the lamp meets the definition of either a “state-regulated LED lamp” or “small diameter directional lamp.” These lamps must be certified to the MAEDBS separately as compliant to the Title 20 requirements, which are different from the Title 24 “high efficacy” lamp requirements. For information on the differences between Title 20 regulations and the Title 24 high efficacy lamp requirements, see the California Energy Commission Blueprint articles located at the following URLs: http://www.energy.ca.gov/2017publications/CEC-400-2017-016/CEC-400-2017-016.pdf and http://www.energy.ca.gov/2016publications/CEC-400-2016-027/CEC-400-2016-027.pdf.

Are retailers responsible for complying with Title 20? How about installation contractors?

Yes and yes. Title 20, section 1609(a)(1) states, “Any person, including a retailer, manufacturer, contractor, importer or distributor, that sells or offers for sale an appliance, which is not listed in the Appliance Efficiency Database, is in violation of Section 1608(a)(1) and may be subject to an administrative civil penalty for each unit of the appliance that was sold or is offered for sale.” Everyone in the supply chain – manufacturers, distributors, retailers, contractors and importers – is responsible for ensuring regulated products are listed in the MAEDBS before they are sold or offered for sale in California. Each party should independently determine applicable regulations for certain product types by referring to the Title 20 regulations.

Are out-of-state retailers required to comply with Title 20 if they sell lighting products to someone in California via online or mail order sales?

Yes. Products sold online or by mail from out-of-state retailers to an end-user in California must meet Title 20 requirements since they are being offered for sale and sold in California. The product models must be listed in the MAEDBS to be legally sold or offered for sale in California.

Can state-regulated LED lamps and state-regulated small diameter directional lamps manufactured prior to January 1, 2018, still be sold in California?

Yes, state-regulated LED lamps and state-regulated small diameter directional lamps manufactured before January 1, 2018, can still be sold in California. These lamp types, as defined in Title 20 section 1602(k) were not required to be certified to the Commission’s database or meet any efficiency standards until January 1, 2018.

Can state-regulated general service lamps manufactured prior to January 1, 2018, still be sold in California?

Yes, general service incandescent and compact fluorescent lamps manufactured before January 1, 2018, can still be sold in California as long as they were marked with a pre-January 1, 2018 date of manufacture and meet the pre-2018 efficiency and marking standards applicable to them. See Title 20, sections 1605.1(k)(3) and (k)(4), Tables K-6, K-7, and K-8; and 1605.3(k)(2), Tables K-11 and K-13.

What percentage of LED lamps currently on the market will not be allowed in California in 2018? In 2019? (For both general service and SDDL)? Have any studies been performed?

Most LEDs currently on the market require modification to meet the state-regulated LED lamp or state-regulated small diameter directional lamp regulations. The Energy Commission found both regulations to be technically feasible and cost-effective for the end user. Two staff reports and additional supporting documents may be found in the Commission’s docket #15-AAER-06 (http://energy.ca.gov/appliances/2015-AAER-06/rulemaking/).

We have portable luminaires manufactured in 2017 that will ship out after the New Year. Are those lamps manufactured in 2017 held to the same 2018 standards?

Portable luminaires prepackaged with a screw-based CFL or LED lamp for each socket and where the lamp was manufactured before January 1, 2018, have no new requirements. If the prepackaged, screw-base LED lamp is manufactured on or after January 1, 2018, then it must meet the state-regulated LED lamp regulations.

Is an LED retrofit kit that does not include an E12, E17, E26, or GU24 base regulated by the California Appliance Efficiency Regulations?

A. No. An LED retrofit kit that does not include an E12, E17, E26, or GU24 base does not meet the definition of a state-regulated LED and does not need to meet any requirements in the California Appliance Efficiency Regulations. The Energy Commission recommends that product documentation not include instructions or discussions about how to attach an adapter, converter, whip, or other means of connecting a screw base to the LED retrofit kit. For installation of LED retrofit kits or other integrated LED recessed trim products in residential new construction, please consult the California Building Energy Efficiency Standards (Title 24, part 6) Joint Appendix 8 (JA8) for additional requirements.


Testing

May a manufacturer group LED lamps for testing purposes?

Yes, if the tested lamp model is the most energy consumptive lamp in the grouping. Manufacturers should carefully consult 10 CFR 429.56 when grouping lamps for testing purposes. For each basic model of LED lamp, a sample of at least 10 lamps must be tested. The same sample, comprised of the same lamps, must be used for testing of all reportable metrics. Upon request, manufacturers must submit a detailed explanation of the grouping to the Energy Commission and all relevant test reports. If a lamp from the grouping is tested by the Energy Commission for enforcement purposes, it must have a luminous efficacy equal to or greater than the representative value as described in 10 CFR 429.56(a)(1)(ii)(A). Additionally, a lamp from the grouping tested for enforcement purposes must meet all of the minimum standards and criteria applicable to the lamp (e.g., color point requirements, CRI, power factor, rated life).

What test procedures should be used for LED lamps that are downlight retrofit kits?

The test procedures used for downlight LED lamp retrofit kits are the same test procedures used for LED lamps, as specified in Table K-1 of Section 1604(k) of Title 20.

May I use test data to certify to the Commission my LED lamp, if the test data that is provided by a test lab was taken before that lab had been approved by the Commission to conduct that test?

Yes, as long as the test lab is approved by the Commission at the time the data is submitted and the test was conducted according to the test procedures specified in Table K-1 of section 1604(k) of Title 20. (See exemption related to estimated rated lifetime, Title 20, section 1606).

Is a minimum of 10,000 testing hours needed to comply with the state-regulated LED lamp requirement for a rated life of 10,000 rated hours or greater?

No. The required test duration is determined by section 4.6 “Calculate Lumen Maintenance and Time to Failure” of the required LED test procedure found in 10 C.F.R. 430.23(ee) (Appendix BB to Subpart B of Part 430).

Are LED lamps with multiple operating modes, such as variable color temperature (CCT) or variable color rendering index (CRI), required to be tested in all operating modes?

No. See section 3.1.4 of the test procedure in 10 CFR 430, Appendix BB to Subpart B of Part 430.

3.1.4. Operate the lamp at the maximum input power. If multiple modes occur at the same maximum input power (such as variable CCT or CRI), the manufacturer can select any of these modes for testing; however, all measurements described in sections 3 and 4 of this appendix must be taken at the same selected mode. The test report must indicate which mode was selected for testing and include detail such that another laboratory could operate the lamp in the same mode.

Can LED lamps with different CCTs be tested as a family, so only the represented model (lowest CCT) needs to be tested?

Yes, LED lamps with different CCT, CRI, or lifetime can be categorized as the same basic model if they have the same efficacy. DOE has noted that all products included in a basic model must comply with the certified values, and products in the same basic model must also have the same light output and electrical characteristics (including lumens per watt) when represented in manufacturer literature. (81 Fed. Reg. 43403, 43416 (July 1, 2016).) Manufacturers and test laboratories should carefully consult 10 C.F.R. section 429.56 when grouping lamps for testing purposes. Also see the first question under Testing, “May a manufacturer group LED lamps for testing purposes?”

Must the power factor be maintained at 0.7 in standby mode (with lamp off)?

See section 3 of 10 CFR 430.23(ee) (Appendix BB to subpart B of part 430). The lamp should be operated at rated voltage and maximum input power when power factor is measured.

What ambient temperature must be maintained during time to failure testing for state-regulated LED lamps and state-regulated small diameter directional lamps?

For test data submitted to the Energy Commission prior to October 22, 2018, the ambient temperature must be maintained at 25 °C ± 5 °C per the required test procedure in section 1604(k), 10 C.F.R. section 430.23(ee) (Appendix BB to subpart B of part 430). For test data submitted to the Energy Commission on or after October 22, 2018, the Energy Commission will accept time to failure data for state-regulated LED lamps and state-regulated small diameter lamps that conforms with the amendments, effective October 22, 2018, to 10 C.F.R. section 430.23(ee) (Appendix BB to subpart B of part 430). These amendments allow maintaining an ambient temperature of 25 °C ± 5 °C or at a manufacturer-selected temperature higher than 25 °C with the same ± 5 °C tolerance. For additional information, see the Final Rule published in the Federal Register at https://www.regulations.gov/document?D=EERE-2016-BT-TP-0037-0005.


Standard

Must an LED lamp be dimmable in order to claim wattage equivalencies with incandescent lamps? Must an LED lamp have CCT of 3000K or less in order to claim wattage equivalencies with incandescent lamps?

No to both questions. Rather, if the manufacturer chooses to make an incandescent wattage equivalency claim for a medium screw base or a GU24 base omnidirectional state-regulated LED lamp, manufactured on or after January 1, 2018, the lamp must have a minimum lumen output as stated in Title 20, section 1607 Table K-15. For reference, see Title 20, section 1607(d)(13)(C). Lamps with other bases or distributions are not required to meet the minimum lumen outputs in Table K-15. Claiming a wattage equivalency is not by itself considered to be a claim of “incandescent equivalence.”

Does a portable luminaire integrated with an LED (integrated luminaire with a built-in LED light source and driver) need to meet the Title 20 state-regulated LED lamp standards?

No. Portable luminaires with integrated LED light sources are not subject to the state-regulated LED lamp standards. Instead, they must comply with the requirements located in Title 20, section 1605.3(n)(3)(A)(3) and Table N-2.

For SDDLs, are there any non-LED lamps that will meet the 2018 standards?

The requirements for small diameter directional lamps are technology agnostic, setting only a minimum efficacy level or a minimum combined efficacy and CRI score, depending on the compliance pathway chosen by the manufacturer. However, the Energy Commission is not aware of any halogen or incandescent technologies that would comply under either compliance pathway.


What’s Covered?

Are color tunable LED lamps required to meet the Title 20 state-regulated LED lamp requirements?

Any mode of operation that produces light with Duv between -0.012 and 0.012 and CCT between 2200K and 7000K must meet the Title 20 state-regulated LED lamp requirements. Modes of operation that produce light outside of these Duv and CCT ranges are not required to meet the Title 20 state-regulated LED lamp requirements. Certification of a tunable LED lamp may be satisfied using one data point within the allowable CCT range.

Which lamp shapes are covered under the standards for state-regulated LED lamps?

The standards for state-regulated LED lamps apply to any shape of lamp – there are no shapes excluded from the standard – and that meet the three criteria below, defined in Title 20, section 1602(k):

  1. The lamp must have an E12, E17, E26, or GU24 base, including LED lamps that are designed for retrofit within existing recessed can housings that contain one of the preceding bases.
  2. The lamp must be capable of producing a quantity of light suitable for general illumination, meaning a brightness less than or equal to 2,600 lumens.
  3. The lamp must be capable of producing white light, meaning light with a correlated color temperature between 2200K and 7000K and with Duv between -0.012 and 0.012.

How do I know if an LED lamp that is used only for special applications is covered under Title 20?

The requirements for state-regulated LED lamps and small-diameter directional lamps are independent of end-use or application and are based only on lamp characteristics. A lamp is covered if it meets the definition of a state-regulated LED lamp or a small-diameter directional lamp per Title 20, section 1602(k).

Do lamps packaged with ceiling fan light kits need to comply with any of the Title 20 lamp requirements?

No. Ceiling fan light kits and the lamps they are packaged with are subject to federal energy and design standards (see 10 C.F.R. 430.2 and 430.32(s)). For example, if an LED lamp is packaged with a ceiling fan light kit, the lamp does not need to meet the Title 20 state-regulated LED lamp requirements. However, ceiling fan light kits must still be certified to the Energy Commission and listed in the MAEDBS to be sold or offered for sale in California.

Are 3-way incandescent lamps packaged and sold with portable luminaires exempt from Title 20?

No. Although 3-way incandescent lamps are not currently regulated by state or federal standards when sold by themselves, they cannot be packaged and sold together with portable luminaires in California. Portable luminaires manufactured on or after January 1, 2010 must meet the applicable testing, performance, certification and marking requirements in Title 20. A 3-way portable luminaire is required to be packaged with a 3-way CFL or a 3-way LED. The light source must meet the minimum efficacy and performance requirements specified in section 1605.3(n). Note that a 3-way LED with an E12, E17, E26, or GU24 base must meet the requirements for state-regulated LED lamps.


Exemptions

What are the exemptions for general service lamps (e.g., 45 lumens per watt)?

As currently defined in T20, general service lamps are incandescent, CFL, LED, and OLED lamps intended for general service applications, having a medium screw base, having a lumen output not less than 310 lumens or more than 2,600 lumens, and capable of being operated at a voltage range at least partially within 110 and 130 volts.

“General service lamps” do not include any general service fluorescent lamps (e.g., linear fluorescent) or incandescent reflector lamps. The following 22 lamp types are also excluded: appliance lamp, black light lamp, bug lamp, colored lamp, infrared lamp, left-hand thread lamp, marine lamp, marine signal service lamp, mine service lamp, plant light lamp, reflector lamp, rough service lamp, shatter-resistant lamp (including a shatter-proof lamp and a shatter-protected lamp), sign service lamp, silver bowl lamp, showcase lamp, 3-way lamp, traffic signal lamp, vibration service lamp, G shape lamp (as defined in ANSI C78.20-2003 and C79.1-2002) with a diameter of five inches or more, T shape lamp (as defined in ANSI C78.20-2003 and C79.1-2002) and that uses not more than 40 watts or has a length of more than 10 inches, and B, BA, CA, F, G16 1/2, G-25, G30, S, or M-14 lamp (as defined in ANSI C79.1-2002 and ANSI C78.20-2003) of 40 watts or less.

“State-regulated general service incandescent lamp” means a standard incandescent or halogen type lamp that: is intended for general service applications; has a medium screw base; has a wattage rating no less than 25 watts and no greater than 150 watts; has a rated voltage range at least partially within 110 and 130 volts; has a A-15, A-19, A-21, A-23, A-25, PS-25, PS-30, BT-14.5, BT-15, CP-19, TB-19, CA-22, or equivalent shape as defined in ANSI C78.20-2003; - Does this mean that if the shape is not defined here that it is exempt from Title 20?

The definition for state-regulated general service incandescent lamp is obsolete because these lamps are now regulated as “general service lamps,” and the previously effective state standard for these lamps has been repealed (See Docket # 13-AAER-1). The definition will be removed from the regulations in the near future.

Specifically - I am looking at a vintage ST shape lamp - the exclusion lists a T lamp, but not an ST shape. Would this be excluded from the general service lamp standard?

If the lamp has a medium screw base, it is likely that the state-regulated general service lamp standard is applicable. Look at the above question “What are the exemptions for general service lamps” for an explanation of lamps for which the regulation is applicable. State-regulated LEDs apply to all lamp shapes that have an E12, E17, E26, or GU24 base and that meet the other criteria specified in the definition in Title 20 section 1602(k).


Labeling and Marking

Are there marking requirements that manufacturers must comply with under Title 20?

Title 20 specifies marking requirements for manufacturers in section 1607(b), which states that the following must be “permanently, legibly, and conspicuously displayed on an accessible place on each unit” of the regulated appliance:

  1. Manufacturer’s name or brand name or trademark
  2. Model number
  3. Date of manufacture, including year and month or smaller increment

Section 1607(c)(2) requires that “the information required in Section 1607(b) shall be permanently, legibly, and conspicuously displayed on an accessible place on each unit, on the unit’s packaging, or, where the unit is contained in a group of several units in a single package, on the packaging of the group.”

There are additional requirements for state-regulated LED lamps marked with certain information related to product performance. These requirements are found in Title 20 Section 1607(d)(13). Note: Title 24, part 6 (JA8) has additional marking requirements for covered lamps that are installed in new residential construction.

Do we have to state the lamp manufactured date on the packaging?

Section 1607(b)(3) and section 1607(c)(2) require the date of manufacture to be marked on an accessible place on the product or the packaging. If the date of manufacture is in code, the manufacture must provide the code to the Energy Commission upon request.