EPA proposes changes for verification testing of Energy Star luminaires that use an LED lamp (Updated)

Certification bodies that must perform annual verification testing on Energy Star luminaires would be able to reuse test data from an LED or other light source that is used in multiple products in lamp or modular form.

The EPA is now proposing changes in the annually required verification testing of luminaires simplifying the process when a number of luminaires use the same lamp. The changes are especially applicable to luminaires that use self-ballasted lamps, such as LED GU24 products that are used in many products from multiple manufacturers. The new proposal would bring functionality similar to that implemented in the Certified Lighting Subcomponent Database (CSD) to the verification testing process.

The US Environmental Protection Agency (EPA) created the CSD to help streamline the Energy Star luminaires qualification process. For example, fluorescent ballasts are in the database simplifying testing for a luminaire that uses a listed ballast. The CSD also includes fluorescent lamps and now self-ballasted LED lamps and light engines.

There are separate certification and verification testing programs for Energy Star. In the case of the luminaires specification, a certification body (CB) must perform the certification testing up front before a lighting manufacturer can use the Energy Star label. Subsequently, the EPA requires each CB to perform annual verification testing on 10% of the base-model luminaires (the base unit in a family for instance) for which the CB has performed certification testing. The CB randomly selects products for verification although the EPA as well as other Energy Star partners can nominate products for verification testing.

To understand the different testing processes, consider the solid-state lighting (SSL) GU24 example that is a recent development. Back in April, MaxLite became the first company to have a GU24-base A19 lamp listed on the CSD. CB Intertek performed the testing. About the CSD and listing of a lamp, Carl Bloomfield, global director of business services for the lighting industry at Intertek, said, "Manufacturers will now experience reduced testing costs and decreased product certification timeframes when launching new Energy Star certified lighting products."

Bloomfield was specifically referring to certification testing alone. Bloomfield explained that a luminaire that uses a replaceable lamp must be tested with a specific lamp when undergoing Energy Star testing, and that the certification only applies to the luminaire and lamp combination. Indeed, manufacturers that ship such a product as Energy Star qualified must ship the lamp and luminaire together.

A luminaire maker that chooses the MaxLite lamp for a new luminaire would be able to take advantage of the existing CSD test data including characteristics such as efficacy, lumen maintenance, and CRI. That streamlined advantage applies regardless of the CB chosen to perform the Energy Star luminaire certification.

Annual verification testing

The verification testing process, however, has lacked any provision to lessen the time and cost impact incurred when a CB performs annual random testing on multiple luminaires that use the same lamp. The EPA is now proposing that that A CB can test a light source once annually and apply that test data anytime a luminaire is verified within a 12-month window.

The luminaires certification and verification processes both require separate testing of the light source, whether it is a lamp with an ANSI base or a modular light engine, and the luminaire with the light source installed. The requirements differ for directional and non-directional luminaires. But the new proposal would allow reuse of the light-source verification test performed by each CB.

The EPA is asking for comments on the proposal to be submitted by August 30, 2013. You can email comments to certification@energystar.gov.

The case of GU24 LED lamps and the CSD also includes one additional unique element compared to other items that are listed in the CSD. A GU24 lamp can be both Energy Star qualified on its own in the lamps program and also listed in the CSD for luminaire usage. But the CSD listing is not contingent on an Energy Star lamps qualification.

Indeed the CSD and Energy Star lamps testing is inherently different. In the case of the CSD, the lamp is tested as a light engine, even though it may have an ANSI base. Obviously a GU24 product is tested as a lamp for standalone Energy Star recognition.

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