State-Regulated LED and Small Diameter Directional Lamps Frequently Asked Questions

January 1, 2018, for state-regulated small diameter directional lamps. State-regulated LED lamps have tiered standards that first went into effect on January 1, 2018, the Tier 2 standards became effective on July 1, 2019.

Yes. Products manufactured before the effective date can still be sold in California. Any products manufactured on or after the effective date are required to be certified to the CEC’s Modernized Appliance Efficiency Database System (MAEDbS) and meet the energy efficiency standards before they can be sold or offered for sale in California.

State-regulated LED lamps are white light LED light bulbs and retrofit kits with E12, E17, E26, or GU-24 bases, including omnidirectional, directional, and decorative lamps.

State-regulated small diameter directional lamps are lamps that are 2.25 inches or less in diameter and include multifaceted reflector lamps (MR16s and MR11s) and parabolic specific aluminized reflector lamps (PAR16s and PAR11s). Directional lamps illuminate specific areas in a particular direction for demanding visual tasks.

For more detailed descriptions, refer to the Definitions section of this FAQ.

The standards for state-regulated LED lamps apply to any shape of lamp (there are no excluded shapes) that meets the three criteria below, per the definition of state-regulated LED lamp (see CCR, 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.
• 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.
• The lamp must be capable of producing white light, meaning light with a correlated color temperature between 2200 kelvins (K) and 7000K and with deep ultraviolet (Duv) between -0.012 and 0.012.

Yes. Any mode of operation that produces light with Duv between -0.012 and 0.012 and correlated color temperature (CCT) between 2200K and 7000K must 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, typically the operating point with maximum power consumption. Modes of operation that produce light outside these Duv and CCT ranges are not required to meet the Title 20 state-regulated LED lamp requirements.

No. 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 the California Building Energy Efficiency Standards (Title 24, part 6) Joint Appendix 8 (JA8) (2016).

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

The requirements for state-regulated LED 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 state-regulated small diameter directional lamp per CCR, Title 20, section 1602(k)(1)

No. Ceiling fan light kits and the lamps they are packaged with are subject to federal energy efficiency and design standards (see 10 C.F.R. sections 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 MAEDbS to be sold or offered for sale in California.

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 lamp and does not need to meet any requirements in Title 20. 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) (2016) for additional requirements.

Yes and yes. CCR, 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 MAEDbS, is in violation of section 1608(a)(1) of this Article 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.

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

For more information you may visit the following links:

• Tier 2 Effective Date Notice for information regarding the Tier 2 standards for state-regulated LED lamps.
• Test Procedure Update Notice for information regarding time to failure data.
• MAEDbS certification packets, which contain detailed information on how to submit data to MAEDbS.
• Docket # 15-AAER-6 for all information pertaining to the rulemaking.
• The California Code of Regulations (CCR), Title 20 for the complete regulations.

The definitions are located in the CCR, Title 20, section 1602(k)(1). Some of the relevant terms include the following:

• “State-regulated light emitting diode (LED) lamp” means a lamp capable of producing light with Duv between -0.012 and 0.012, and that has 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. State-regulated LED lamp does not include a lamp with a brightness of more than 2,600 lumens or a lamp that cannot produce light with a correlated color temperature between 2200K and 7000K.

• “State-regulated small diameter directional lamp” means a directional lamp that meets all of the following criteria:
  (1) Capable of operating at 12 volts, 24 volts, or 120 volts;
  (2) Has an ANSI ANSLG C81.61-2009 (R2014) compliant pin base or E26 base;
  (3) Is a non-tubular directional lamp with a diameter of less than or equal to 2.25 inches;
  (4) Has a lumen output of less than or equal to 850 lumens, or has a wattage of 75 watts or less; and
  (5) Has a rated life greater than 300 hours.

  State-regulated small diameter directional lamp includes incandescent filament, LED, and any other lighting technology that falls within this definition. State-regulated small diameter directional lamp does not include directional lamps with an E26 base that utilize LEDs and are covered under the definition of state-regulated LED lamps.

• “Directional lamp” means a lamp that has at least 80 percent of light output within a solid angle of Π steradian corresponding to a cone with an angle of 120°.

CCR, Title 20, section 1604(k)(3) states that the required test method is 10 C.F.R. section 430.23(ee) (Appendix BB to subpart B or part 430). For certification, compliance, and enforcement purposes, the sampling provisions in 10 C.F.R. section 429.56 shall be used. There are optional test methods in Table K-1 of CCR, Title 20, section 1604(k)(4). These optional test methods may be required depending on the manufacturer’s claims of performance as described in CCR, Title 20, section 1607(d)(12).

The test procedures used for downlight LED lamp retrofit kits are the same test procedures used for state-regulated LED lamps, as specified in CCR, Title 20, section 1604(k)(3).

Yes, if the tested lamp model is the most energy consumptive lamp in the grouping. Manufacturers should carefully consult 10 C.F.R. section 429.56 when grouping lamps for testing. For each basic model of LED lamp, a sample of at least 10 lamps must be tested. The same sample, composed 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 CEC and all relevant test reports. If a lamp from the grouping is tested by the CEC for enforcement purposes, it must have a luminous efficacy equal to or greater than the representative value as described in 10 C.F.R. section 429.56(a)(1)(ii)(A). Furthermore, a lamp from the grouping tested for enforcement purposes must meet all the minimum standards and criteria applicable to the lamp (for example, color point requirements, color rendering index [CRI], power factor, rated life).

Yes. LED lamps with different color coordinated temperature (CCT), color rendering index (CRI), or lifetime can be categorized as the same basic model if they have the same efficacy. The U.S. Department of Energy (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 previous question under Testing, “May a manufacturer group LED lamps for testing purposes?”

No. See section 3.1.4 of the test procedure in 10 C.F.R. 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.”

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

No. See section 3 of 10 C.F.R. section 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.

The CEC will accept time to failure data for state-regulated LED lamps and state-regulated small diameter directional 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.

Yes. The data may be used as long as the test lab is approved by the CEC at the time the data are submitted and the test was conducted according to the test procedures specified in CCR, Title 20, section 1604(k). Before the lab can become approved, they must declare in their test lab application that they have performed the specified test procedure within the last 12 months.

State-regulated LED and small diameter direction lamps have energy performance standards for rated life, efficacy, compliance score, and other parameters. For the complete performance standards, refer to CCR, Title 20, section 1605.3(k).

(Note: State-regulated LED lamps have tiered standards. The initial standards became effective on January 1, 2018. Then, on July 1, 2019, more stringent Tier 2 standards for compliance score and efficacy became effective.)

Yes. CCR, Title 20, section 1605.3(k)(2)(A) says that the following state-regulated LED lamps are exempt from the energy performance standards:*

• E12 base lamps with a lumen output less than 150 lumens
• E17, E26, or GU24 base lamps with a lumen output less than 200 lumens

*Although these lamps do not have to comply with the energy performance standards, they are still regulated and must comply with the testing, marking, and certification requirements for state-regulated LED lamps.

The requirements for small diameter directional lamps are technology-neutral and do not prohibit any light source type, setting only a minimum efficacy level or a minimum combined efficacy and color-rendering index score, depending on the compliance pathway chosen by the manufacturer. However, the CEC is not aware of any halogen or incandescent technologies that would comply under either compliance pathway.

CCR, Title 20, section 1607(b) states that the following must be “permanently, legibly, and conspicuously displayed on an accessible place on each unit” of the regulated appliance:

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

Note: For lamps, CCR, Title 20, section 1607(c)(2) allows the required markings to be placed on either the lamp or its packaging.

For state-regulated LED lamps, there are additional requirements that must be met before a lamp can be marked with certain information related to product performance (for example, claims that the lamp is dimmable or equivalent to an incandescent). These requirements are in CCR, Title 20, section 1607(d)(12).

• Must an LED lamp be dimmable to claim wattage equivalencies with incandescent lamps? Must an LED lamp have a CCT of 3000K or less 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 specified in Table K-15 in CCR, Title 20, section 1607(d)(12)(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.”
• Can I compare an LED lamp to an incandescent lamp (for example, state “incandescent replacement” or similar on the packaging) when the LED lamp has a CCT higher than 3000K? What if the LED lamp is nondimmable?
  • 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: having a warm CCT, being fully dimmable, and having a certain level of brightness (lumen output). See CCR, Title 20, section 1607(d)(12)(B) for the requirements to claim incandescent equivalency. Making a claim of wattage equivalencies has separate, independent requirements, which are addressed in the previous question.

Yes. State-regulated LED lamps and state-regulated small diameter directional lamps are both required to be certified to MAEDbS before they can be sold or offered for sale in California. Certification packets are available, which contain a template Excel sheet that can be used to submit the data and PDF instructions sheets on how to use MAEDbS and submit data.

Yes. The lamp must be certified separately to the Title 20 requirements. Certification to MAEDbS for Title 24 (Building Energy Efficiency Standards) represents compliance with that program, not compliance with the requirements in Title 20, which is the Appliance Efficiency Program that regulates the sale of appliances in California. The Title 24 “high-efficacy” requirements (also referred to as JA8) apply to residential lamps and luminaires and differ from the Title 20 requirements and product coverage outlined here. State-regulated LED lamps that meet JA8 are not lawful for sale in California after January 1, 2018, unless they are certified to MAEDbS as compliant with Title 20. While there is some testing overlap, it is recommended that test laboratories review both requirements when testing LED lamps. The LED lamp must be listed in the MAEDbS to comply with Title 20.