Lack of action on LM-79 allows companies to exploit loophole
Despite minor changes to labelling requirements for LED-based MR16 lamps, consumers will still be confused, write Tim Whitaker and Brian Owen.
The Lighting Facts label for this product (ECS16 WW FL) says you'll get 295 lumens from it. You take it home, pop it into the waiting socket and…the output is much less than 200 lumens. Around two-thirds the light output you expected.
What do you do? Live with it? Ask for a refund? Chalk it up to experience and go back to CFLs? Become a lighting expert so you don't get fooled again? Contact the Federal Trade Commission?
The problem here is all related to AC and DC operation. As we explained in our article "AC-DC rocks the boat for LM-79 and LED replacement lamps", MR16s can operate from either AC or DC, but the vast majority of lamps will be connected to an AC supply.
However, the light output when operated at 12V DC can be significantly higher than the value when operated at 12V AC, as was the case with this LSG lamp. Pretty much everyone taking the lamp home will experience the lower value of light output, because they will almost certainly connect the lamp into an AC infrastructure.
But guess what? LSG has used the much higher, DC-measured test results on its Lighting Facts label, rather than the AC numbers.
Once the issue came to light, the Lighting Facts program acted quickly and said that all manufacturers must state on their label whether the data was measured at AC or DC. The Lighting Facts website entry for the ECS16 WW FL product now carries the text “tested at 12V DC,” and similar text will appear on the packaging of new lamps.
But how does that help consumers? The answer is that it doesn't; despite the best intentions of Lighting Facts, it just adds to the confusion.
Most consumers will not know whether their MR16 will be connected to DC or AC at home. Most will not be able to compare two sets of data when one is measured at 12V AC and the other at 12V DC. Most will just look for the highest number, without understanding the small print.…but if the number is measured at DC there is very little chance they will ever actually see that level of light output.
Both LSG (see Footnote 1) and The Home Depot are happy to hide behind the changes made by Lighting Facts. A spokesperson from The Home Depot told us that the store “will place signs in the stores that communicate the change [to Lighting Facts label] in an effort to make sure our customers have the latest information.”
Of course, there's nothing to stop LSG publishing the AC-measured test values on its Lighting Facts labels, and The Home Depot could insist this is done to avoid its customers being given misleading information.
So why are DC-measured numbers used at all? Because the LM-79 testing protocol apparently allows MR16 lamps to be tested at either AC or DC. LM-79 says that “the SSL product under test shall be operated at the rated voltage (AC or DC) according to the specification of the SSL product for its normal use.” Since 12V MR16 LED lamps can be used with AC or DC, this wording allows manufacturers to test at either AC or DC.
The IESNA technical committee responsible for LM-79 is evaluating whether it could, or should, change the wording of LM-79 to help clarify this situation. However, feedback from IES suggest they would prefer programs such as Lighting Programs and Energy Star to be proscriptive (possibly, for example, not allowing DC test results for MR16s). But the programs do not see this as being part of their role.
Speaking of Energy Star, the approval of MR16 lamps was temporarily put on hold while EPA assessed the problem. As explained in Footnote 2, EPA has also come up with an approach which both relies on the changes to Lighting Facts and may, in some cases, require additional small print.
So, in the (hypothetical) case where an MR16 might qualify for Energy Star when tested at DC, but would not qualify when tested at AC, the lamp package needs to say "incompatible with AC" or similar. Again, this creates the potential for consumer confusion.
We mentioned the Federal Trade Commission (FTC) earlier in this article, and it's worth noting that, in September of this year, the FTC sued Lights of America over deceptive claims for LED lamps. The FTC said that LOA and its principals had been misleading consumers by exaggerating the light output and life expectancy of its LED bulbs. This action was taken even though, in October 2009, LOA issued a recall notice to customers that had bought its products in Costco, a major retail store. We wait to see what – if any – action The Home Depot will take.
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Footnote 1: Statement from LSG
Lighting Science Group Corporation told us: “The packaging on all new shipments of MR16s will be updated as a result of recent labeling changes by Lighting Facts. Since this adjustment just occurred, Lighting Facts is not asking Lighting Science Group to update existing packaging that's already on the market. However, Lighting Science Group is working with Home Depot to place signs in the stores that communicate the change in an effort to make sure our customers have the latest information. All of Lighting Science Group’s marketing materials for the MR16 have been updated and the company’s LM-79 report for the bulb does state that it was 12 volt DC tested by an independent laboratory approved by the US Department of Energy’s CALiPER program.”
Footnote 2: Statement from EPA on Energy Star
Alex Baker, who runs the EPA Energy Star for Lighting program, told us: "The Lighting Facts label is the primary vehicle for informing the consumer about Energy Star qualified MR16 integral LED lamp performance, as it is required on product packaging for Energy Star qualified lamps not covered by FTC lamp labeling requirements. That program has adjusted their label requirements to reflect the type of input power provided during testing, which will be reflected on the packaging of Energy Star qualified lamps."
In addition to the Lighting Facts change, EPA is addressing the issue with reference to page 8 of the Energy Star specification for integral LED lamps. This states that the "lamp package must clearly state any known incompatibility."
Baker said: “If a qualified lamp operating on AC or DC does not comply with requirements, that is also an application exception which should be detailed by the manufacturer. Therefore, on the lamp packaging (not on enclosed materials, not on a referenced website), language similar to the following should be included: 'Not intended for AC operation' or 'Not intended for operation on AC transformers' or 'Not for use with AC transformers'...where 'DC' could be substituted for 'AC', as applicable."
"Language in the LED MR-16 Lamps Intended for use on Low-Voltage Circuits section (also page 8) supports this, as that section explains that incompatibility shall be detailed on packaging, while compatibility may be detailed on a website."