Beginning October 22, 2018, the California Energy Commission will begin accepting data for state-regulated integrated light emitting diode (“LED”) lamps and state-regulated small diameter lamps that conform with amendments to LED “time to failure” testing procedures recently approved by the Department of Energy.
Under the Energy Policy Conservation Act, the DOE regulates the energy efficiency of certain consumer products and industrial equipment. Under those federal regulations, manufacturers of covered products must follow certain requirements for energy efficiency testing procedures in order to make representations regarding the efficiency of their products. These testing requirements include specifications for the operational and environmental conditions during testing.
The DOE’s amended testing procedure changes the time to failure test for LEDs by setting an ambient temperature of 25 °C + 5 °C or at a manufacturer selected temperature higher than 25 °C with the same + 5 °C tolerance. (See 10 CFR 430, subpart B, appx BB, § 4.4.4.) While higher ambient temperatures have a greater negative effect on performance values, allowing manufacturers to test higher than 25 °C allows manufactures to avoid test duplication in order to meet the standards required under the federal Energy Star program for the Elevated Temperature Life Test for LEDs, which has a higher ambient temperature requirement.
If you have any questions regarding California’s regulation of LEDs or other questions regarding California’s standards for energy efficient appliances, please contact ESHD attorneys Jeff Harris, Brian Biering, or Chase Maxwell at 916-447-2166.
