A guide to some of the biggest changes in regulations & standards impacting residential lighting.
By David Shiller
Lighting regulations and standards have a large impact on the lighting industry. Regulations such as California Title 24 and Department of Energy (DOE)’s General Service Lamp final rule set minimum performance requirements that manufacturers can’t ignore. While standards such as ENERGY STAR, UL safety, and NEMA/ANSI are voluntary in name, when the market comes to expect it, changes in standards can have a similar impact to changes in law. At the same time, U.S. tariff policy raises product costs and/or leads to disruptions in the global supply chain.
According to Michael Weems, VP/Government Engagement for the American Lighting Association (ALA), “Today, the most pressing issues are tariffs, GSL rule-making, and Prop 65. Tariffs are, by far, the number one issue for all [ALA] membership categories.”
As of press time, U.S. tariff policy with China seems to be changing every week with escalating tariffs and delaying effective dates. ( To get the latest on U.S. tariff policy affecting the lighting industry, go to www.enltransfer.wpengine.com and search tariffs, or visit the ALA’s tariffs page at https://alamembers.com/Government-Engagement/Tariffs.
Weems notes, “The U.S. imports roughly $550 billion worth of goods from China annually. Presently, additional tariffs, as part of the trade war, have been placed on the vast majority of the $550 billion. By the end of the year, it is expected that the entire amount will have additional tariffs.”
Weems adds, “Despite reports, the tariffs have cost Americans. The costs include loss of R&D and innovation, loss of jobs, and higher prices on goods. Manufacturers have been scrambling, almost daily, trying to keep up with all of the tweets, adjusting price sheets. This volatility has created confusion and uncertainty for showrooms, specifiers, and ultimately consumers.”
In early September, the U.S. DOE issued a final rulemaking on general service lamps (GSL) and general service incandescent lamps (GSIL). DOE reversed an earlier Obama-era plan to expand the definition of general service lamps to cover at least half of the decorative and reflector lamps sold today. DOE’s final rule decided that GSL and GSIL will remain the original definition, in the EISA’07 law. Therefore, all of the decorative and reflector lamps that the Obama Administration tried to get regulated as GSL & GSIL will remain unregulated at this time.
Weems shares the ALA’s views on this DOE final rule: “DOE mistakenly approved new definitions for GSLs and GSILs in 2017. The ALA appreciates the actions taken by DOE to return to statue and Congressional intent. The recent final rule on GSL and GSIL definitions was not a rollback of standards; DOE could not have been clearer about that in the final rule. At the same time DOE released the GSL definition final rule, it also released a proposed determination on the necessity of new standards for GSILs. DOE determined that new regulations are not economically viable. Sometimes government regulation is needed to move an industry along, and other times consumer demand and market forces are enough to spur action. In the lighting industry, the latter is the case. Today’s consumers, through showrooms, have access to products and knowledge that are efficient, innovative, and highly functional.”
In the final rule, DOE also clarified that an EISA’07 provision to raise efficiency requirements on GSL to 45 lumens per watt (lm/W) in 2020, was not triggered. This raises questions about if, and when, halogen A-lamps will be phased out with a 45 lm/W requirement, known as “the backstop.” This issue remains unresolved.
The ALA is actively working with the State of California to get Prop 65 regulatory relief to the lighting industry doing business in California. According to Weems, “ALA is engaged with OEHHA to develop regulatory relief for the lighting industry as it relates to Proposition 65. ALA had an introductory meeting with the Director, Chief Deputy Director, and Chief Counsel of OEHHA, asking for assistance in getting a safe use determination (SUD). After making our pitch, the OEHHA officials suggested an easier (and less costly) approach to eliminating prophylactic warnings. For the main swath of fixture offerings, the OEHHA officials encouraged us to pursue a document called ‘Interpretive Guidance’ (IG). This document is not a get-out-of-jail-free card, but an OEHHA- and hopefully CA Attorney General-approved document that provides some level of protection from frivolous lawsuits. Upon receipt of the IG, ALA would petition OEHHA’s chief counsel to issue a Chief Counsel Letter indicating that it is the opinion of the Chief Counsel that based on the IG, no warnings are required to be provided in lighting showrooms. ALA and OEHHA agreed that SUD may still be necessary for certain product categories such as crystal chandeliers.”
The new CA Title 24-2019 becomes effective January 1, 2020. This newest version had many fewer lighting changes than past revisions to the CA energy code. It added solar panel requirements for all new homes, including JA11 solar specs and JA12 battery storage specs.
For lighting, exemptions were added for step lights and path lights that are <5W, and <150 lumens. GU24 CFLs are no longer exempted from JA8. It allows for any LED source to be installed outdoors, not requiring integrated nor JA8 sources. Light sources internal to drawers, cabinetry, or linen closets will not be required to comply with Table 150.0-A nor be controlled by vacancy sensors, if <5W and <150 lumens, and automatic control turns lights off when the drawer/cabinet/closet is closed. CEC only aligned CRI for T24 & T20 and not CCT.
Weems remarks, “ALA was pleased to see that lighting was not a direct target of this version. However, there are some changes to be aware of:
Clarifies the requirements for controlling luminaires with JA8 sources
JA8 elevated temp testing revised to align with ENERGY STAR
JA8 sources must be labeled “JA8-2019” or “JA8-2019-E”
Allows a max of 4000K for all JA8 light sources
Removes the GU24 CFL exemption from JA8
Weems adds, “While these are not like the major changes we have seen in the past, manufacturers and retailers should still take notice.”
A new tier of Title 20 state-regulated LED lamps (SLEDs) became effective on July 1, 2019. This raised the minimum compliance score and minimum efficacy required for SLEDs. CRI is no longer required to be 90+ CRI (+R9>50) for T20 lamps. SLED in T20 require >82 CRI and with R1-R8>72.
There is a major change for small-diameter directional lamps (SDDLs) since there is now no explicit CRI requirement in T20, rather the compliance score combining efficacy and CRI. Similarly, Title 24 no longer requires 90 CRI for JA8. Looking forward, the California Energy Commission (CEC) is looking to have Title 20 set performance requirements for non-regulated GSFL (fluorescent tubes).
In addition, there is a new cybersecurity law in California (called “CCPA”) that can impact smart lighting products that collect consumer data.
Weems reveals, “The way cybersecurity has always been handled is no longer satisfactory. Consumers continue to do more online – by direct and indirect interaction – and the practices used to protect user data needs modernizing. It has become too easy for companies to collect, store, sell, or lose user data. It seems like every day a new breach of user data has occurred. In hopes of preventing these breaches as well as giving consumers better access to the information collected by online companies, the EU and California have taken swift action to enact broad cybersecurity protections.”
Weems adds, “With any government action there will be some good and some bad.”
Starting last year on January 1, 2019, GSL sold in Canada have to meet a new 45 lm/W requirement, that will phase out halogen A-lamps. Also, the province of British Columbia (BC) recently passed Amendment 6 that creates new requirements for CFLs, GSIL, general service LED lamps, and small-diameter directional lamps (SDDL), such as some MR16s.
Weems says the following about changing regulations in Canada, “NRCan continues to update efficiency regulations, harmonizing as best as possible with those of the USA. ALA has worked closely with NRCan ensuring that lighting-related products are not adversely affected during the course of this work. Additionally, ALA continues to engage at the provincial level to ensure regulatory efforts do not contradict the work of NRCan.”
Recently ENERGY STAR finalized its Smart Home Energy Management System specification, known as “SHEMS.” Weems comments, “ENERGY STAR is an enigma. The program is currently under constant threat by the Trump Administration. Manufacturers are certifying fewer products because of out-of-touch specifications and testing requirements. Consumers are turning less to ENERGY STAR products as LED products generally improve on efficiency. Yet, project specifiers, designers, builders, and building codes are requiring ENERGY STAR products. Eventually something is going to have to give. The ENERGY STAR SHEMS specification, ALA’s Lighting and Homes for Tomorrow competition and other utility programs will continue the push toward incorporating a systems approach for connected devices — including lighting.”
ADDITIONAL STANDARDS CHANGES
Some Zhaga books are transferring to IEC standards. There is a new joint certification program between Zhaga and DiiA (DALI), plus there are seven new Zhaga books in development.
The NEMA/ANSI C-137 Lighting Systems Committee is developing standards to cover interoperability for lighting control protocols and data tags. The C-137 committee has approved a digital interface standard for DALI, with an outdoor focus; meanwhile 0-10V dimming standards to aid interoperability are close to completed.
There are UL changes for TLEDs, Types A and A/B hybrids. Furthermore, efforts are underway to move light and human health research findings into the mainstream of lighting design. UL is developing a standard practice with the Lighting Research Center (see http://alturl.com/fn6ub) and The WELL Building Standard has incorporated “healthy lighting” into its building design requirements (see https://www.wellcertified.com).
REGULATIONS LOOKING FORWARD
When asked to make predictions about regulatory changes in the future, Weems points out, “With it being November, the election is one year away. The future of regulatory activity could be nothing or could be everything should the political winds bring a new occupant to the White House.”
Special thanks to Michael Weems and Terry McGowan of the ALA, for their assistance.