ALA Answers Questions About Title 20 & 24 Changes
In order to simplify the changes taking place in California regarding lighting legislation in 2017, the American Lighting Association (ALA) compiled a list of questions from its Engineering Committee meeting – as well as from the participants of a Webinar plus e-mail inquiries – and provided answers to help members sell their products in California and in compliance with the California Title 24 Building Standard.
Additional information regarding future changes – slated to go into effect January 2018 and July 2019 – is included so that ALA manufacturers can also prepare for the new Tier 1 and Tier 2 requirements, respectively, in the Title 20 Appliance Standard. Both Title 24 and Title 20 reference what the California Energy Commission (CEC) calls “joint appendices,” which contain detailed test and performance requirements.
- What are Title 20 and Title 24 all about?
Both are comprehensive energy regulations, which contain sections that apply to
residential lighting. Title 20 is an appliance regulation, and so regulates electrical
products of all types, including lamps (bulbs), LED bulbs, portable fixtures, torchieres
and lighting controls, plus several other types of lighting products. Title 20 is enforced
by the CEC and products must be listed on the newly named California MAEDBS
Database to be legally sold in California even if the seller is out-of-state.
Title 24 is a building regulation that applies to all buildings in California, including
residential buildings whether the project is a new home or remodeling project. If a
building permit is issued for the work, Title 24 applies. Title 24 is enforced by the local
building inspector, who looks for properly labeled lamps in permanently wired lighting
fixtures or properly marked integrated LED fixtures at the time of the final inspection.
All fixtures installed in residential construction starting Jan. 1, 2017, are required to
be “high efficacy” as defined by Title 24.
- What documents contain the lighting regulations and how can they be obtained?
- Title 20: The full document for the new version of Title 20 that becomes effective on Jan. 1, 2018, is not yet available. So-called “Express Terms” for Small Diameter “Directional Lamps,” Portable Luminaires and General Service LED Lamps are at:
The current version (2016) of Title 20 and associated documents can be found here:
http://www.energy.ca.gov/appliances/
The products that this document regulates include lamps (bulbs), ballasts, torchieres, portable fixtures, lighting controls, ceiling fans, and ceiling fan light kits.
- Appliance Efficiency Database (MAEDBS)
http://www.energy.ca.gov/appliances/forms/index.html#webdocs
List of Data Certification Forms & Instructions for Manufacturers’ Lighting Products (use to enter performance data and register LED luminaires, LED lamps, other lamps-all permitted types, portable lamps, ceiling fan light kits, lighting controls, torchieres)
http://www.energy.ca.gov/appliances/database/forms_instructions_cert/Lighting_Products/
To search the database for products, go to:
https://cacertappliances.energy.ca.gov/Pages/ApplianceSearch.aspx
- Title 24: 2016 Building Energy Efficiency Standards for Residential and Nonresidential
Buildings
http://www.energy.ca.gov/2015publications/CEC-400-2015-037/CEC-400-2015-037-CMF.pdf
Click on the item in the Table of Contents to go directly to the section of interest. Residential
lighting is in Section 150.0. Table 150.0-A (Page 244) and below, which defines “High Efficacy” light sources and fixtures, is particularly important. Note that any permanently wired fixture with standard screw-base sockets or other standard socket types is considered “high efficacy” if it contains high-efficacy light sources at the time of inspection. Fixture manufacturers do not have to test or mark such fixtures and they are not required to be sold with bulbs.
- 2016 Title 24 Residential Compliance Manual – Chapter 6, Residential Lighting
This CEC publication – dated January 2017 – is easier to read than the wording of Title 24 itself and simplifies the sections on fixtures, controls and installation requirements. There are sections with guidance for building inspectors and lists of such things as how inspectors can confirm that all the fixtures in the building are “high efficacy.” The publication also summarizes the requirements in JA8, lists some pitfalls and includes several Q&A.
- 2016 Reference Appendices
http://www.energy.ca.gov/2015publications/CEC-400-2015-038/CEC-400-2015-038-CMF.pdf
The appendices apply to both Title 20 and Title 24. Light source performance requirements are in JA8 – Qualification Requirements for High Efficacy Light Sources and JA10 – Test Method for Measuring Flicker of Lighting Systems
- Residential Lighting Guide
Written by the California Lighting Technology Center (CLTC), this is a new edition of a lighting and design guide for choosing and specifying Title 24-compliant products. The material in the Guide will be particularly helpful to builders and contractors, but manufacturers and showrooms will also find it useful.
- How are Title 20 and Title 24 enforced?
Title 20 is enforced by the CEC itself based upon its own investigations of non-complying products or submitted reports that identify incidents of such products as being sold in California. That includes products from retailers outside of California who sell and ship a non-complying product to a customer in California. Penalties, which may be substantial, are levied upon the manufacturer/retailer/distributor – whomever sells the product – and are based upon the number of products sold rather than an “incident” or shipment that might contain numerous products. Title 24 is enforced by the building or electrical inspector at the site of the lighting installation and may involve the homeowner and the contractor/builder. The building permit process is used to identify and track compliance. If a lighting installation is non-compliant as installed, an occupancy permit may be delayed or denied.
- How do I know if a lighting fixture is “high efficacy” or “low efficacy” as per Title 24?
The requirements are summarized in Table 150.0-A or go to Title 24 (Page 244) or to the Title 24 Residential Compliance Manual, Section 6.9. The key qualification to remember is that fixtures designed to be permanently wired and which are equipped with standard screw-base or other standard socket types are automatically considered to be “high efficacy.” They don’t need to be tested or marked and the packaging does not need to be specially labeled.
- Are downlights with screw bases considered “high efficacy?”
No. In fact, downlights are a special case and they may not be equipped with screw sockets.
They must be IC-rated, tested, and marked for air leakage and must use certain bulbs and sockets — including LED bulbs meeting JA8 requirements that have a GU-24 base.
- Do outdoor lighting fixtures have to be “high efficacy?”
Yes, but LED fixtures installed outdoors – which means fixtures attached to the residence itself or to other buildings on the same lot – are exempt from the general residential lighting requirement that all LED fixtures for residential lighting must meet the requirements of Joint Appendix JA8.
- Are there any lighting fixtures that have to be tested to meet Title 24?
Yes. The so-called “inseparable” or “integral” LED fixtures – those with permanent light engines – have to be photometrically tested and marked as meeting the requirements of JA8. They also have to be registered on the CEC’s MAEDBS database.
- Is there an “official” definition of what the CEC means by “Inseparable” SSL
or LED fixture?
Yes, near the beginning of Title 24, there is a definitions section.
The definition is:
INSEPARABLE SOLID STATE LIGHTING (SSL) LUMINAIRE is a luminaire featuring solid
state lighting components, such as LEDs and driver components that cannot be easily
removed or replaced by the end user, thus requiring replacement of the entire luminaire.
Removal of solid state lighting components may require the cutting of wires, use of a
soldering iron, or damage to or destruction of the luminaire.
- In my showroom I have fixtures with G9 sockets. Can I still sell these in California?
Yes, they can be sold, but if they are not equipped with bulbs that meet JA8 at the time of
inspection after they are installed, the building inspector cannot, according to the law, approve the project. To avoid returns and builder/contractor problems, it is in your best interest to be sure that JA8-certified bulbs are available for such fixtures, but it is not your problem to ensure that they have been installed. You can check for certified bulb products yourself by searching the MAEDBS database. Go to:https://cacertappliances.energy.ca.gov/Pages/ApplianceSearch.aspx
- Even though it’s not required, can I ship JA8 certified lamps with my fixtures?
Yes.
- What should I look for to be sure that bulbs that I recommend or include with the fixture are JA8-certified?
Two things. (1) The bulb must be listed on the MAEDBS database and (2) the bulb must be
permanently marked with one of two markings “JA8-2016” or “JA8-2016-E.” The latter indicates a bulb designed for high-temperature conditions such as in enclosed fixtures.
- When did the CEC start qualifying bulbs and fixtures to JA8?
The instructions were posted and the database page accepted listings starting in late October. There were over 500 JA8 qualified products as of the middle of December 2016, mostly LED fixtures.
- Is there any “grandfather” period for fixtures that are currently Title 24-approved so that they can be installed in new construction?
No. Those fixtures have to be requalified if they utilize integral LEDs.
- How do I list LED lighting tape on the MAEDBS database?
Define a base model of the product, say a certain number of feet, and submit the data for that. If there are options that include a channel or lens, these variations probably don’t have to be measured and submitted separately since the performance of the basic light source and driver set the performance level. However, work with your test lab to define the base model and minimize the number of variations.
- How are low-voltage systems measured, such as a fixture with several low- voltage LEDs with drivers and a transformer feeding the whole array?
The fixture has to be measured as a complete system with the transformer included.
- Do the new JA8 requirements essentially eliminate fluorescent lamps (linear lamps and screw-in CFLs)?
No. Check Title 24, Table 150.0-A. CFLs with GU-24 bases may be used in fixtures as well as pin-based linear and compact fluorescent lamps. All must be powered by electronic ballasts. They do not have to meet JA8 requirements.
- If I make an LED-integrated fixture with a colored art glass shade so the light being emitted cannot meet the JA8 efficacy or color requirements, can that fixture be certified?
The entire fixture has to be tested to determine if it meets the JA8 requirements, but the shade can be removed or tested with clear glass installed so as to accurately test the light source. The commercial testing labs can provide more guidance.
- For testing, can I group fixtures that are similar or use the same components so I don’t have to test every fixture variation?
Yes. Check with your testing lab. You can also get instructions for grouping products from the MAEDBS certification packet. See:http://www.energy.ca.gov/appliances/database/forms_instructions_cert/Lighting_Products/
- To be listed on the MAEDBS database, does the manufacturer have to submit
a certified testing reports or just state that the products were tested in a certified lab?
The CEC has what they call a “declaration of compliance,” which is executed by the
manufacturer under penalty of perjury. If the data are questioned, the manufacturer must be
able to produce a report from a certified lab to back up the information that they have
entered.
- I make decorative fixtures that use integral colored LEDs. Can they be sold in California?
Yes. There is an exception for LED fixtures that use colored LED sources for decorative
lighting. See Table 150.0-A.
- Previous versions of Title 24 required a certain percentage of “high efficacy” fixtures in certain rooms. Is that still a requirement?
No, not in single-family homes. All fixtures in every room must be “high efficacy.”
- Does the CEC’s “California Quality LED Lamp Specification” have anything to do with Title 20 or Title 24?
Not directly and not immediately. The specification is intended to be a preview of future LED light source requirements. It’s a voluntary specification developed jointly by the CEC and the
California Public Utilities Commission (CPUC) that describes the performance levels of lights
sources that might be expected to qualify for utility rebates and, eventually, be required by
Title 20 (LED bulbs) and Title 24 (integrated LED fixtures).
- How often are Title 20 and Title 24 revised?
Generally, on a three-year cycle although updates and changes may occur between updates.
- If an integral LED fixture meet ENERGY STAR requirements, does it also meet Title 24?
No. Even though some of the same test procedures and test reports may be used to qualify
fixtures, Title 24 and JA8 generally require higher performance levels particularly for efficacy
and color rendering.
- Appendix JA10 indicates that the CEC requires a special flicker test of LED
bulbs and integrated LED fixtures in order to qualify products to JA8. Who
does such testing and is there measurement equipment available so testing
can be done in house?
Yes, this is a new and California-only test procedure and calculation. Some commercial
labs are now set up to do the work, but the calculations are complex and go beyond the capabilities of typical spreadsheet software. The work can be done in house, but special test equipment and software – such as MATLAB – are required.
- How can I contact the CEC directly to ask a question about Title 20 or
Title 24?
For Title 20 and the MAEDBS database, start here: Appliance Efficiency Hotline at
888-838-1467 (toll free in California), 916-651-7100 (outside California), or via email at
For Title 24: Energy Standards Hotline at 800-772-3300 (toll free in California),
916-654-5106 (outside California), or via email at title24@energy.ca.gov
Looking for more information regarding the changes taking place as of January 1, 2017? Terry McGowan spoke to enLIGHTenment Magazine about what the residential lighting industry can expect next.
https://enlightenmentmag.com/inside-lighting/new-lighting-regulations
The policing of Color Temperature and CRA above 90% are clearly designed to rule out foreign light suppliers. Track lighting that meets JA8-2016 is up to 6x more expensive, but not more energy efficient AT ALL.