Going forward, MR16 and MR11 replacement lamp submissions will be required to indicate the tested input voltage, including AC or DC operation, within the model number field on the Lighting Facts label.
The message circulated from Lighting Facts on October 12 is shown below:
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Dear Lighting Facts Partner:
It has recently been brought to our attention that some manufacturers of MR16 and MR11 LED replacement lamps may be presenting misleading performance data on Lighting Facts labels by submitting LM-79 test data corresponding to the DC-powered operation of products, while the typical end-use of the products may be predominantly on AC circuits, where the product performance may be significantly different than the DC-tested version.
Lighting Facts accepts product submissions covered under the scope of LM-79, which includes both AC-powered and DC-powered products. However, when the submitted test results of a product do not represent the typical end-use configuration and performance of the product, the potential to mislead product buyers exists.
To maintain the integrity of the program and to ensure trust in the Lighting Facts label, we will now require all MR16 and MR11 replacement lamp submissions to indicate the tested input voltage, including AC or DC operation, within the model number field on the Lighting Facts label, as such: "tested at 12V DC", "tested at 12V AC", or "tested at 120V AC." If a product has multiple modes of operation, you will have to submit test data for each mode in order for it to be listed on the Lighting Facts label. Operating modes that produce different performance values will need to be submitted for separate labels.
For existing approved MR16 and MR11 products, we have already made the necessary changes to your online product information and your updated labels are ready to be downloaded. Please login to www.lightingfacts.com as soon as possible to download your updated labels so you can begin updating your marketing materials and packaging. Because of the large effort involved, we are not asking you to update existing packaging that's already on the market, but all other materials, including not-yet-released packaging, as well as cut sheets, spec sheets, and other web materials should be updated.
For all future MR16 and MR11 submissions, you will need to include the input voltage and designate AC or DC within the model number field before the submission can be approved. It is our hope that this action will increase the accuracy of performance information available to product buyers and will decrease the potential for confusion in the market. We appreciate your continued commitment to truth in advertising for solid-state lighting. Please direct any questions about this notice to firstname.lastname@example.org.
Sincerely, The Lighting Facts Product Verification Team
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