Frequently Asked Questions:
State-Regulated Lamps

If clarification is needed on any of the information contained in the FAQ document, please contact the Appliance Efficiency Program via email at: with the following title in the subject line: State-Regulated Lamps FAQ.

Must an LED lamp be dimmable in order to claim wattage equivalencies with incandescent lamps?

No. However, if the manufacturer chooses to make an incandescent wattage equivalency claim for a medium screwbase or a GU-24 base omnidirectional state-regulated LED lamp, manufactured on or after January 1, 2018, the lamp shall have a minimum lumen output as stated in Title 20 section1607 Table K-15. For reference, see Title 20 section 1607(d)(13)(C).

What test procedures should be used for LED lamps that are downlight retrofit kits?

The test procedures used for downlight LED lamp retrofit kits are the same test procedures used for LED lamps, as specified in Table K-1 of Section 1604(k) of the Title 20 Appliance Efficiency Regulations.

May I use test data to certify to the Commission my LED lamp, if the test data that is provided by a test lab before that lab had been approved by the Commission to conduct that test?

Yes, as long as the test lab is approved by the Commission at the time the data is submitted.

Does a portable luminaire integrated with an LED (integrated luminaire with a built-in LED light source and driver) need to meet the Title 20 state-regulated LED lamp standards?

No. Integrated portable luminaires are not subject to the state-regulated LED lamp standards. Instead, integrated portable luminaires must comply with the requirements located in Title 20 section 1605.3(n)(3)(A)(3) and meet the requirements set out in Table N-2.

Is a minimum of 10,000 testing hours needed to comply with the state-regulated LED lamp (SLED) requirement for a rated life of 10,000 rated hours or greater?

No. The required test duration is determined by section 4.6 “Calculate Lumen Maintenance and Time to Failure” of the required LED test procedure found in 10 C.F.R. 430.23(ee) (Appendix BB to Subpart B of Part 430).

Are LED lamps with multiple operating modes, such as variable color temperature (CCT) or variable color rendering index (CRI), required to be tested in all operating modes?

No. See section 3.1.4 of the test procedure in 10 CFR 430, Appendix BB to Subpart B of Part 430.

3.1.4. Operate the lamp at the maximum input power. If multiple modes occur at the same maximum input power (such as variable CCT or CRI), the manufacturer can select any of these modes for testing; however, all measurements described in sections 3 and 4 of this appendix must be taken at the same selected mode. The test report must indicate which mode was selected for testing and include detail such that another laboratory could operate the lamp in the same mode.

Are color tunable LED lamps required to meet the Title 20 state-regulated LED lamp requirements?

If the lamp is capable of producing light with Duv between -0.012 and 0.012, and has an E12, E17, E26, or GU-24 base, including LED lamps that are designed for retrofit within existing recessed housings that contain one of the preceding bases, then it must meet the Title 20 state-regulated LED lamp requirements.

Which lamp shapes are covered under the standards for state-regulated LED lamps?

The standards for state-regulated LED lamps apply to lamps of any shape that meet the four criteria below, defined in Title 20 § 1602(k), and this includes LED downlight retrofit kits and candelabra LEDs.

  1. The lamp must have an American National Standards Institute (ANSI) standard E12, E17, E26, or GU24 base, including LED lamps that are designed for retrofit within existing recessed can housing that contains one of the preceding bases.
  2. The lamp must be capable of producing a quantity of light suitable for general illumination, meaning a brightness less than or equal to 2,600 lumens.
  3. The lamp must be capable of producing white light, meaning light with a correlated color temperature between 2200K and 7000K.
  4. The lamp must have a Duv ±0.012.

How do I know if an LED lamp that is used only for special applications is covered under Title 20?

The requirements for state-regulated LED lamps and small-diameter directional lamps are independent of end-use or application, and are based only on lamp characteristics. A lamp is covered if it meets the definition of a state-regulated LED lamp or a small-diameter directional lamp per Title 20 Section 1602(k).

Do the definitions recently adopted by the U.S. Department of Energy and published in the Federal Register on January 19, 2017 apply to Title 20?

No. All relevant definitions are included in Title 20, Section 1602(k).

If an LED lamp is certified for Title 24 “high efficacy” lamp requirements, does it need to be certified again for the Title 20 requirements?

Yes. The lamp must be certified separately to the Title 20 requirements. Certification to the MAEDBS for Title 24 (Building Energy Efficiency Standards) represents compliance with that program, not compliance with the requirements in Title 20, which is the Appliance Efficiency Program that regulates the sale of appliances in California. The Title 24 “high efficacy” requirements (also referred to as JA8) apply to residential lamps and luminaires, and differ from the Title 20 requirements and product coverage. A lamp that meets JA8 may not meet the efficacy (compliance score) required in Title 20. State-regulated LED lamps that meet JA8 are not lawful for sale in California after January 1, 2018 unless they are certified to the Energy Commission as compliant with Title 20. While there is some testing overlap (both primarily reference IES LM-79), it is recommended that test laboratories review both requirements when testing LED lamps. The LED lamp must be listed in the MAEDBS to comply with Title 20.

Are retailers responsible for complying with Title 20? How about installation contractors?

Yes and yes. Everyone in the supply chain – manufacturers, distributors, retailers, contractors and importers – is responsible for ensuring regulated products are listed in the MAEDBS before they are sold or offered for sale in California. Each party should independently determine applicable regulations for certain product types by referring to the Title 20 standards.

Are out-of-state retailers required to comply with Title 20 if they sell lighting products to someone in California via online or mail order sales?

Yes. Products sold online or by mail from out-of-state retailers to an end-user in California must meet Title 20 requirements since they are being offered for sale and sold in California. The product models must be listed in the MAEDBS to be legally sold or offered for sale in California.

Are there marking requirements that manufacturers must comply with under Title 20?

Title 20 specifies marking requirements for manufacturers in Section 1607(b), which states that the following must be “permanently, legibly, and conspicuously displayed on an accessible place on each unit” of the regulated appliance:

  1. Manufacturer’s name or brand name or trademark
  2. Model number
  3. Date of manufacture, including year and month or smaller increment

Section 1607(c)(2) includes further guidance on marking for lamps stating that “the information required in Section 1607(b) shall be permanently, legibly, and conspicuously displayed on an accessible place on each unit, on the unit’s packaging, or, where the unit is contained in a group of several units in a single package, on the packaging of the group.”

There are additional requirements for state-regulated LED lamps marked with certain information related to product performance. These requirements are found in Title 20 Section 1607(d)(13).

Do lamps packaged with ceiling fan light kits need to comply with any of the Title 20 lamp requirements?

No. Ceiling fan light kits and the lamps they are packaged with are subject to federal energy and design standards (see 10 C.F.R. 430.2 and 430.32(s)). For example, if an LED lamp is packaged with a ceiling fan light kit, the lamp does not need to meet the Title 20 SLED requirements. However, ceiling fan light kits must still be certified to the Energy Commission and listed in the MAEDBS to be sold or offered for sale in California.

Are 3-way incandescent lamps packaged and sold with portable luminaires exempt from Title 20?

No. Though 3-way incandescent lamps are not regulated by state or federal standards (when sold by themselves), they cannot be packaged and sold together with portable luminaires in California. Portable luminaires manufactured on or after January 1, 2010 must meet the applicable testing, performance, certification and marking requirements in Title 20. A 3-way portable luminaire is required to be packaged with a 3-way CFL or a 3-way LED. The light source must meet the minimum efficacy and performance requirements specified in section 1605.3(n).