ENERGY STAR Criteria for Compact Fluorescent Lamps (CFLs) Meeting
Overview and Notes

U.S. Department of Energy Headquarters\
April 29, 2003 \~ Washington, D.C.

[ENERGY STAR Introduction and Program Overview]{.underline}

Richard Karney, U.S. Department of Energy's (DOE) ENERGY STAR Program
Manager, gave initial introductions and explained the purpose and goals
of the meeting. DOE's goal for this revision of the ENERGY STAR CFL
Criteria is to "raise the bar" of the program and maintain the quality
and integrity of the ENERGY STAR label, since the ENERGY STAR CFL
Program and the number of ENERGY STAR qualified products have grown
since the last criteria revision in Fall 2001. In addition, DOE is not
impressed with the results of the Program for the Evaluation and
Analysis of Residential Lighting's (PEARL) fourth cycle test results and
those products not meeting the ENERGY STAR criteria will be removed from
the qualified product list.

**[Review of the 2^nd^ Draft of the Revised ENERGY STAR Criteria for
CFLs]{.underline}**

Ron Lewis took the floor and explained the purpose of this part of the
meeting was to review the 2^nd^ draft of the criteria as well as collect
additional comments and suggestions. Ron emphasized that the 2^nd^ draft
includes comments that have been received thus far and is by no means a
final document.

## Page 1, Partner Commitment Overview 

### Bullet 6: Quarterly update list of ENERGY STAR qualifying CFL models 

*Ron Lewis, DOE*: Purpose is to ensure accuracy of product list,
regardless if any new models are being added or changes to packaging is
made.

[Industry Comments:]{.underline}

*Matt Donati, Philips Lighting*: Reporting products bi-annually seems
repetitive. Product information should be complete when the product test
reports and packaging is submitted. This increases work to submit a
separate list of product numbers.

*Susan Gardner, D&R International*: The main objective is to be sure all
records are fresh and accounted for, even if the product packaging
changes.

*Matt Donati, Philips Lighting*: Philips contacts ENERGY STAR if the
packaging changes, so this is redundant.

*Noah Horowitz, NRDC*: Up-to-date information is important as it wastes
time if de-listed products or removed products are tested by PEARL.

*Gary Crawford, GE Consumer Products*: Supports bi-annual submission,
rather than quarterly because providing the list becomes repetitive and
burdensome.

*Chris Granda, VEIC*: Sees list as a very helpful tool for utility
programs. Supports quarterly submittal or review of qualified products.

*Mark Sharp, Panasonic*: This requirement ensures and prevents errors.
List is an accurate reflection of qualified products. Supports quarterly
submittal or review of qualified products.

**Bullet 9: Shipment/Product Sales Data**

*Ron Lewis, DOE*: Having this information helps to prove success of the
program. ENERGY STAR is a federal program that uses taxpayer money and
ENERGY STAR needs to supply information showing the success of the
program, both on regional and national levels. Emphasized that this
requirement is a part of the current ENERGY STAR partnership agreement.
Once the partnership agreement is signed, partners make the
acknowledgement that they understand and agree to provide this
information. DOE is not interested in individual numbers, but the
aggregate number information to provide a solid basis to showcase the
market share of ENERGY STAR products. In addition, DOE ensures the
highest confidentiality on the submitted shipment and/or sales data.

[Industry Comments:]{.underline}

*Aaron Feit, Feit Electric*: No shipment or sales data has been given
out to date. Lacks confidence the submitted data would not be released
into the wrong hands. Suggested that ENERGY STAR should investigate
other avenues to obtain shipment and/or sales data information.

*Glenn Reed, NEEP*: Supports shipment and/or sales data submission
requirement because information is critical to ENERGY STAR utility
lighting programs. Need sales data to show success and impact of ENERGY
STAR, especially in the Northeast. Suggested to have a 'third party'
hold of the confidential shipment and/or sales data, as the ENERGY STAR
Appliance Program does. In addition, requested to have shipment and/or
sales data collected on a state-by-state basis.

*Collin Cremo, Costco*: Supports data requirement. Has shared past,
present, and future sales data with ENERGY STAR and utilities. Sees no
problem with releasing shipment and/or sales data as long as the
specific organization names are not associated with aggregated data.

*Lee Bodner, D&R International*: Explained how the ENERGY STAR Appliance
program works -- D&R International acts as the 'third-party' and signs a
confidentiality agreement with the participating ENERGY STAR partner
that is supplying the appliance market data. Data is released in
aggregate form only.

*Rebecca Foster, CEE*: Collection of sales data and market indicators is
extremely important to utility programs since they need to show the
movement of the market to the regulatory organizations. Currently, many
utilities use their own funding to purchase or collect the
shipment/sales data in their service territories. If a national process
is developed, it would save funding so the utilities could put it
towards more rebates, consumer education, training, etc.

*Gary Crawford, GE Consumer Products*: In response to Glenn Reed's
comment about state-to-state data, obtaining product shipment data is
difficult on the state level, since shipments are sent to one location
and then distributed to a multitude of locations.

*Noah Horowitz, NRDC:* Supports the collection of product shipment
and/or sales data and suggests developing a data collection template so
consistent information will be submitted.

*Ron Lewis, DOE*: Intent of requirement is not to burden partners, it is
to help maintain the integrity of the program and build a system to
generate a market view of how ENERGY STAR CFLs compare to other
residential lighting products.

*Aaron Feit, Feit Electric*: When collecting shipment and/or sales data,
cautioned ENERGY STAR that retailers and manufacturers could submit
duplicate product information and should build in check system to avoid
duplicate collection.

*Tasso Kostelidis, Conglom*: Asked how specific should the data be.
Should the information be collected by product category or type?

*Ron Lewis, DOE*: Stated that DOE has general guidelines on what
information the program is looking for -- product type/design, total
number of product shipped, and percent of total unit shipments that
qualify as ENERGY STAR. DOE has not finalized these parameters and
stressed that this requirement is not trying to add on more work for
partners' efforts to collect and submit shipment data (ENERGY STAR is
aware that most manufacturers are submitting their shipment data to
NEMA).

*Peter Bleasby, NEMA*: Can provide direction and assistance in
development of a shipment and/or sales data-reporting template.

*Glenn Reed, NEEP*: Suggested that D&R International develops a
reporting template and circulate to partners.

# [Page 3, Program Requirements]{.underline}

*Ron Lewis, DOE*: Noted the criteria change within 1) Scope section:

\- Removed "single-based" and replaced with medium based.

[Industry Comments:]{.underline}

*Rebecca Foster, CEE*: Suggested that candelabra-based models be
included in the criteria.

*Aaron Feit, Feit Electric*: Supports idea of adding candelabra-based
models, but cautions that DOE needs to carefully examine the lumens per
watt criteria for candelabra-based models. Lumens Per Watt should be
different than the current levels for the medium-based ENERGY STAR
qualified CFLs.

*Greg Murphy, MaxLite*: Agrees that candelabra-based models are
included, but new requirements should not be developed for this
base-type. Candelabra-based CFLs should be able to meet the current
efficacy requirements.

*Paul Rorer, Westinghouse*: Agrees that candelabra-based models be
included.

*Collin Cremo, Costco*: Agrees that candelabra-based models be included
and they should have dimming capabilities since most are used in
chandeliers.

[**Page 3-4, Definitions:**]{.underline}

*Ron Lewis, DOE:* Asked for suggestions on how to simply or enhance the
definitions, especially for color appearance.

#### Page 4, Reference Standards

*Ron Lewis, DOE:* Asked for assistance from industry to review
identified reference standards to make sure we have the most current
versions.

[Industry Comments:]{.underline}

*Ed Yandek, NEMA:* Provided information on ANSI/IEE C62.41 - 1999
standard has been updated.

# [Page 5, Photometric Performance Requirements]{.underline}

### [Efficacy and CRI for Niche Application CFLs]{.underline}

*Ron Lewis, DOE*: Pointed out that efficacy levels have not changed from
the original criteria because this revision of the criteria is targeted
to solidify the criteria, rather than raising the bar too. In addition,
the CRI for Colored CFLs requirement was removed since the comments that
were received during the 1^st^ comment period did not support the
inclusion of these models.

[Industry Comments:]{.underline}

*Paul Rorer, Westinghouse*: It is worth discussing including colored
CFLs in the criteria further, especially for bug lights. However, a
different set of criteria (efficacy, CCT, CRI, lumen maintenance) will
be needed if colored lamps are to be incorporated.

*Ed Yandek, GE Lighting*: Agrees with Paul -- if colored CFLs are to be
included in the criteria, all of the test requirements need to be
reviewed to see if the criteria levels need to be adjusted.

*Collin Cremo, Costco*: Supports the idea of including special
requirements for colored CFLs, but feels the program needs to prioritize
and decide if it is worth spending time researching these special
products, since they are a small percentage of the overall CFL market.

#### Sample Size

*Ron Lewis, DOE*: The focus of the ENERGY STAR Criteria for CFLs is
directed at increasing the quality of the products that are qualified as
ENERGY STAR. The sample size for ENERGY STAR qualification testing is
suggested to increase from 5 to 10 - 5 tested in the base-down position
and 5 tested in the base-up position, unless the manufacturer calls out
the product is restricted to a specific position, then the product
should be tested in that position only.

[Industry Comments:]{.underline}

*Ed Yandek, GE Lighting*: Is unsure of the rationale on this suggested
change. The Federal Trade Commission (FTC) requires no more than a 5%
difference in lumen output/efficacy and the lesser of the base-up and
base-down is the efficacy of the product. If the sample size changes to
10, would need to make sure the base-up and base-down data is recorded
separately. In addition, would changing the sample size to 10 cause
additional burdens and costs to the manufacturers?

*Ron Lewis, DOE*: ENERGY STAR needs to gain a better picture of the
qualified products and requiring samples to be tested in both base-up
and base-down positions will help to verify all position orientations
provide results that are above the ENERGY STAR requirement.

*Noah Horowitz, NRDC*: PEARL will only test 5 CFL samples, so will need
to coordinate with ENERGY STAR on which position PEARL should test in
(base-up or base-down).

*Aaron Feit, Feit Electric*: If the sample size doubles, does the number
of acceptable failures increase too?

*Rebecca Foster, CEE*: Supplying 10 samples for testing should not be a
burden to manufacturing partners.

**[Correlated Color Temperature (CCT)]{.underline}**

*Ron Lewis, DOE:* The CCT requirement has been revised to suggest
requiring specific CCT levels for qualified CFLs, as they do in the
commercial lighting market. This suggestion was incorporated into the
criteria to provide a more stringent requirement to address the color
issues with CFLs.

[Industry Comments:]{.underline}

*Dale Work, NEMA:* Why would you suggest this detailed of a requirement?

*Aaron Feit, Feit Electric*: This requirement does not allow for a
measurement tolerance. The proposed revision does not allow for lamps to
fall between or outside a temperature range. Based upon our experience,
lamps very rarely average or measure EXACTLY 2700K, 2850K, 3000K, 4100K
or 6500K. As a matter of fact, I think this will be impossible for any
manufacturer. In addition, there are lamps that are made specifically at
2650K or 2750K or 3100K etc. Based upon this proposed requirement, a
\"warmer\" lamp of 2650K would not be able to meet the requirement.
Lamps should be allowed to fall outside the specific color temperatures
as long as the packaging clearly states the temperature (in Kelvin) and
the corresponding color.

*Ed Yandek, GE Lighting*: Agrees with Feit -- most lighting
manufacturers, when labeling a product as 2700K, usually have a
tolerance range between 150-200 K. Would like to see a clearer
indication as to what DOE is trying to accomplish for the CCT
requirement. If objective is to tighten up the control of color matching
of different CFLs (as the commercial lighting products have done), it
will come at a very high cost.

Asked if the CFL criteria would adopt an acceptable tolerance range like
the ENERGY STAR qualified light fixtures criteria?

Suggested the criteria should provide a range of color for manufacturers
to meet, using the ANSI standards (look at the x and y axis
measurements).

*Gary Crawford, GE Consumer Products*: Does Kelvin temperature matter to
a consumer? If so, then this will require a lot of consumer education.

*Chris Granda, VEIC*: Need to think about the customer perspective and
expectations -- suggests setting ranges of CCT levels to help group the
same color CFLs together.

*Collin Cremo, Costco*: Has experience with customers returning CFLs
because the color and/or light output does not match what is currently
in their home, which demonstrates that customer perception is extremely
important. Also supports adding the inclusion of the specific CCT and
CRI on the product packaging as an ENERGY STAR qualification
requirement.

*Dave Shiller, EPA*/*Rebecca Foster, CEE*: Contend that Kelvin
temperature and accuracy of information that is on the package help
ensure the integrity of ENERGY STAR qualified products and meeting
customer expectations.

*Peter Bleasby, Osram Sylvania*: Quality of light will be an issue --
incandescent lamps follow the black-body loci and CFLs cannot follow the
black-body loci.

*Ron Lewis, DOE*: DOE is aware that CCT is a complex issue. The main
objective of this suggested revision was to solicit ideas on how to
decrease the dissatisfaction of customer experience. Some of the
alternatives that have been discussed are to use temperature ranges or
provide a list of those acceptable definitive temperatures. Tolerance
will not be an issue until CCT is more clearly defined and further
discussion and research will be required before a final decision can be
made.

*Ed Yandek, NEMA*: Suggested that DOE consider a three-category approach
by providing temperature ranges attached to the mainstream fluorescent
terminology: warm white -- 2650-2800K, soft white -- 2700-3000K, and
cool white -- 3100-4100K.

*Tom Cohen, Greenlite*: Consumers will not change out a halogen for a
2700K CFL model. Also need to be aware of different ethic communities
and their perceptions -- for example, in Miami, you cannot sell a 2700K
CFL because the Hispanic community does not like the warm light, they
prefer CFLs in the higher CCT ranges (4100-6000K).

*Aaron Feit, Feit Electric*: Just need to ensure that the correct Kelvin
temperatures match the specified temperature ranges.

*Noah Horowitz, NRDC*: How can we make sure the color of CFLs will be
consistent over the same product? For example, if a consumer purchases a
4-pack of CFLs, they should all have the same light and color output.

*Ed Yandek, GE Lighting*: Associating temperatures to a color range is
difficult because it is subjective and to address the consistent color
issue across the same product, there is a high probability that the
color output would be similar in a multi-pack since the products were
produced during the same production run. The issue comes into play when
you have two products that were manufactured at different times or at
different manufacturing facilities.

*Ron Lewis, DOE*: Suggested to make an acceptable suggestion on behalf
of the manufacturers for a color criteria change.

# [Dimmable CFLs Testing]{.underline}

*Rebecca Foster, CEE*: Suggested incorporation of a testing protocol
requirement for dimmable CFLs. The requirement would require the test to
dim the CFL down to 30% light output then back up to 100%.

*Glenn Reed, NEEP:* Supported incorporating a 100%-30% dimming/lumen
maintenance requirement into the test procedure. Need to look at
performance issues, especially at lowest wattage rating. Experience has
shown some CFL products become unstable on low wattages.

# 

# [Page 6, Electrical Performance Requirements]{.underline}

#### Power Factor

*Terry Pang, PG&E*: The CA utilities are in support of higher power
factors for ENERGY STAR qualified CFLs.

#### Run-Up Time

[Industry Comments:]{.underline}

*Noah Horowitz, NRDC*: Would like to reduce to requirement to 1 minute,
but is concerned that other characteristics may be sacrificed.

*Greg Murphy, MaxLite*: Changing the requirement to 1 minute would
remove many amalgam CFLs from the market. Even though they need
additional time for run-up, they provide many benefits -- amalgam CFLs
can be used in recessed cans, outdoor, and others since their design can
handle a wide range of low to high temperatures. Different types of
climate environments will effect the run-up time. By reducing the run-up
time, it could limit where CFLs can be marketed. Suggests manufacturers
should label their products that contain amalgam.

*Collin Cremo, Costco*: Believes a 3-minute requirement is too long --
it should be decreased. Has seen some PAR38 reflectors that are still
using mercury in their bulb design with run-up times less than 1 minute.

*Matt Donati, Philips*: 3 minutes allows for more flexibility in
different environments.

*Aaron Feit, Feit Electric*: The amalgam technology is available and can
generate less than 1-minute run-up time. Asked what the average run-up
time among all the ENERGY STAR qualified models is? If a majority of
them are under 3 minutes, suggested taking the average and base the
requirement on that.

*Ed Yandek, GE Lighting*: Questioned what is a reasonable run-up time,
and asked ENERGY STAR to query product information to determine a
reasonable time. And agreed the environmental conditions where CFLs
could be used varies and a faster start-up time could decrease the
market.

#### Transient Protection

[Industry Comments:]{.underline}

*Dale Work, Philips Lighting*: NVLAP labs could use different
requirements for test since NVLAP does not certify for transient
protection.

*Jacki Swiernik, ITS*: Historically, this test does not see many
failures - not a difficult test to pass.

*Ed Yandek, GE Lighting*: ANSI C62.41 -- 1999 is under review.

*Ron Lewis, DOE*: If revisited, this test could remain as
Self-Certification versus requiring a NVLAP laboratory to perform the
test.

#### Compatibility with Controls

[Industry Comments:]{.underline}

*Conan O'Rourke, LRC/RPI*: Suggested non-compatibility sounds negative
and the labeling should clearly state what the CFL product can be use
with or is compatible with.

*Ed Yandek, GE Lighting*: UL requires negative statements on packaging
to prevent product failures. If products are compatible with certain
applications, like dimmers or 3-way fixtures, it will be highlighted
clearly on the packaging.

# [Page 7, Lifetime Performance Requirements]{.underline}

#### Warranty

*Ron Lewis, DOE*: Considering a two-year warranty requirement to provide
additional quality assurance for ENERGY STAR products, since they are
'above and beyond' standard products. Also, wanted to create some
consistencies between the ENERGY STAR qualified fixtures program and the
CFL program. Currently ENERGY STAR qualified light fixtures require a
2-year warranty.

[Industry Comments:]{.underline}

*Aaron Feit, Feit Electric*: Stated a 2-year warranty will outlast a
6,000-hour ENERGY STAR qualified CFL if left turned on 24 hours a day. A
6,000-hour model will run out in 8-10 months.

*Ed Yandek, GE Lighting*: Suggested that the term 'limited' be added to
the warranty language to follow the FTC labeling guidelines.

*Chris Granda, VEIC*: In response to the Feit Electric comment,
consumers need to be aware that most guarantee and/or warranty
statements are based on average 3-4 hour daily use, which equates to the
product lasting 6 years. A model that is constantly 'on' could
potentially last longer because you are not switching it off/on (which
affects life of bulb).

*Greg Murphy, MaxLite*: Stated that the warranty issue could potentially
have adverse effects on manufacturer's relationships with the commercial
sector, especially hotels, since they will want to hold the manufacturer
liable to their warranty claim.

*Richard Karney, DOE*: The packaging should specifically mention 3-4
hour average residential use to prevent this.

*Aaron Feit, Feit Electric*: Supports the MaxLite statement and pointed
out the uniform daily use of product is not currently part of the
warranty requirement.

*Susan Gardner, D&R International*: Suggested to add the 3-4 hours/day
claim to the warranty requirement to provide clear guidance for
consumers and also pointed out the majority of manufacturers already use
this use claim on their existing packaging.

*Tom Cohen, Greenlite*: Supports 2-year warranty requirement -- believes
it will help drive the ENERGY STAR CFL market.

*Mark Sharp, Panasonic*: Two-year warranty requirement does not fit well
with the commercial market. Suggests adding in a commercial use warranty
to clarify what manufacturers are responsible for based on the
application and use.

*Greg Murphy, MaxLite*: Suggests offering different warranty levels for
the different rated lifetimes -- the 2-year warranty could apply to the
higher rated (8,000- 12,000 hours) and a 1-year warranty would cover the
6,000-hour models.

*Matt Donati, Philips Lighting*: Need to incorporate a standard
disclaimer for how long a CFL will last, based on its rated lifetime.
Suggests using 6,000 hour = 5 years; 8,000 hours = 7 years; 10,000 hours
= 7 years.

*Noah Horowitz, NRDC*: Suggests keeping the market standardized by
stating the CFL last "X" years if used "X" hours per day.

*Glenn Reed, NEEP*: Supports 2-year warranty, but favors longer warranty
based on longer life of the model. Package also needs to clearly state
average usage for residential application. Offered a suggestion of also
placing an 800-phone number on model itself, because consumers typically
do not save packages.

*Paul Rorer, Westinghouse*: Pointed out that as the CFL bulbs are
designed smaller and smaller, there will not be room to provide
additional information on the base.

*Greg Murphy, MaxLite*: Believes if a consumer has a complaint, they
will find a way to contact the manufacturer by using the Internet,
catalogs, etc.

**[CFL/Incandescent Equivalency:]{.underline}**

*Ron Lewis, DOE*: In an effort to standardize the incandescent to CFL
equivalency numbers used on packaging, DOE is suggesting to require
using the existing equivalency chart (based on lumen output) in the
criteria (on page 9) if a manufacturer will be making an incandescent to
CFL equivalency statement. If the manufacturer chooses not to make this
type of claim, then this would not be a requirement for qualification.

[Industry Comments:]{.underline}

*Collin Cremo, Costco*: Stated that this information needs to be
provided and emphasized and that guideline standards are needed to help
provide consistent messaging.

*Gary Crawford, GE Lighting*: Asked DOE to clarify what ENERGY STAR
expects the rated lumen output to be on the packaging. Example, does DOE
want 840 lumens if a model meets 840, or is 800 okay?

*Aaron Feit, Feit Electric*: Informed DOE that chart on ENERGY STAR web
site is not consistent with chart in criteria. Web chart is being used
my utilities for rebate programs which contradicts what ENERGY STAR is
trying to achieve.

*Tasso Kostelidis, Conglom*: Asked if there were any considerations to
adding the other design types (reflectors, globes) to the chart. Tasso
feels that DOE needs to identify more clearly their lumen performance
and create different criteria for these models.

*Ron Lewis, DOE*: Suggested the possibility of creating separate charts
for lumen maintenance based for reflectors and globes/decorative CFLs.

#### Rapid Cycle Stress Test

*Ron Lewis, DOE*: This test was removed in the first draft of the
revision, but based on the overwhelming support received during the
first round of comment; DOE has added this requirement back into the
criteria.

[Industry Comments:]{.underline}

*Rebecca Foster, CEE*: Strongly supports keeping this test requirement
as part of the overall criteria.

**[Interim Life Test]{.underline}**

*Ron Lewis, DOE*: With much of the emphasis targeted at increasing the
quality of the CFL products, DOE is suggesting to decrease the amount of
sample failures from 3 to 2.

[Industry Comments:]{.underline}

*Chris Granda, VEIC*: Supports the suggested revision -- providing
partners a 20% failure rate for ENERGY STAR qualification is not
sufficient (existing criteria allows 2 failures).

*Ed Yandek, GE Lighting*: Does not support suggested change because you
must incorporate some room for non-characteristic product failures, such
as product being dropped, damaged, etc. and should be excused if there
is a clear explanation.

*Rebecca Foster, CEE*: Suggests requiring a product "autopsy" if there
is one failure to check on why it failed. If there are two failures, it
is sufficient for removal of its qualified product status.

*Tasso Kostelidis*, Conglom: As long as a manufacturer is clear in their
life rating, the 40% interim tests should indicate the quality of model.

*Ron Lewis, DOE*: Suggested to add in the further information to clarify
what specific information manufacturers would need to supply DOE on
early failures.

**[Page 8, Qualification:]{.underline}**

*Ron Lewis, DOE:* Based on strong feedback on the first criteria
revision, DOE has changed the suggested submission process from only
full qualification to submission of test results at 40% of rated life
and then the final average rated life.

[Industry Comments:]{.underline}

*Aaron Feit, Feit Electric*: Prefers the current criteria process
because by eliminating Early Labeling option, DOE would be preventing
new products from reaching the market quickly, which would be a
disservice to partners.

*Chris Granda, VEIC*: Asked what motivated DOE from going from a 3-step
qualification process to 2.

*Rich Karney, DOE:* PEARL test results and partner reports demonstrate
that many CFL products, which meet the initial qualification step, fail
either the lumen maintenance or interim life time tests, and in turn,
creates many issues which can potentially damage the credibility of
ENERGY STAR. The suggestion of Full Qualification submission assures
that the CFL product has met ALL of the requirements. But, after
reviewing all of the partner and stakeholder comments, DOE realized this
option would not be advantageous to partners or the program. DOE wanted
to compromise and is offering submission at 40% of rated life so that
the time requirement to get qualified products out to market is
decreased significantly and should aid in keeping poor products from
achieving ENERGY STAR qualification status. DOE believes the program is
tarnished when products are on the shelves and then removed due to
performance issues. It not only questions the integrity of the label,
but also manufacturers' reputation.

*Chris Granda, VEIC*: Supports the suggested change mainly because
utilities put a great deal of money into marketing and supporting the
ENERGY STAR program.

*Peter Bleasby, Osram Sylvania:* Asked if keeping the 1,000-hour lumen
maintenance requirement is redundant since all partners would have to
submit the 40% lumen maintenance to achieve ENERGY STAR qualification.
What is the rationale for keeping both test requirements?

*Susan Gardner, D&R International*: Keeping both 1,000-hour and 40%
lumen maintenance test requirements is key to assure that all ENERGY
STAR qualified CFLs do meet 90% light output at 1,000-hours and 80% at
40% of rated life. We have seen examples where a product meets one but
not the other. Keeping both tests adds another quality assurance
dimension to the criteria.

*Ron Lewis, DOE*: Suggested adding specific language to the criteria to
state there is a 20-30 day window for the submission of test results.

#### Page 9, Private Labeling

*Ron Lewis, DOE*: Privately labeled products for residential markets
must display the rated product information on the packaging as well as
the ENERGY STAR designation. Commercial bulk packaging would be treated
differently and may not require all product information.

[Industry Comments:]{.underline}

*Noah Horowitz, NRDC*: Stated that with many manufacturers private
labeling products from each other, asked if there was a system in place
to share this information with PEARL to help aid in product selection
for 3^rd^ party testing -- so the same products are not tested at the
same time.

*Aaron Feit, Feit Electric:* Paragraph 8 should be changed to say that
equivalency is not necessary for the packaging, but if included, it must
be the information provided in the criteria's incandescent/CFL
equivalency graph.

# [Commercial packaging of products]{.underline}

*Ron Lewis, DOE*: Since the ENERGY STAR criteria for CFLs is directed
towards the residential market, the criteria requires packaging
information that is directed at consumers, but for commercial customers,
they may not be interested in this or it is not cost-effective to ship
products in individual packaging. To help aid in providing product to
commercial customers, DOE has suggested requiring the shipping box to
contain all the ENERGY STAR labeling requirements.

[Industry Comments:]{.underline}

*Aaron Feit, Feit Electric*: The warranty for commercial products must
be clarified.

# [Quality Assurance/Retirement and/or Unqualification/Discontinuation of CFL Products]{.underline}

[Industry Comments:]{.underline}

*Matt Donati, Philips Lighting*: In the criteria, it calls out for full
qualification for retesting. But there is no clarification to stop a
manufacturer from reintroducing the same product but at a different
wattage or lifetime.

*Rebecca Foster, CEE*: Commented that the removal of the six-month
waiting time is the wrong direction, should add that delay back in for
products that are removed from the qualification product list.

*Ron Lewis, DOE*: DOE wants strict criteria, so that is why it has
incorporated the full qualification requirement for re-listing a
product. Manufacturers should be reminded that multiple de-listings
could jeopardize the Partnership Agreement.

*Gary Crawford, GE Lighting*: If model is unqualified, what about stock
inventory with the ENERGY STAR logo on it? What are DOE's expectations
as to what should happen with those products?

*Ron Lewis, DOE*: Stated that there was no way for DOE to control
inventory, or determine how long inventory is in market. The objective
is to show what models meet do and do not meet ENERGY STAR. DOE offers
window of opportunity to allow partners to remove product from shelves
or cover up the ENERGY STAR logo. The responsibility lies with the
partners.

*Collin Cremo, Costco*: If the retailers are stuck with inventory that
is not ENERGY STAR qualified, they will not eat the cost of those
products.

*Aaron Feit, Feit Electric*: Suggested a procedure to handle products
that lose their ENERGY STAR qualification status. Manufacturers would
place a "stop shipment" on the specific product immediately so it cuts
off that product entering into the retail market further. With this
suggestion, you would need to build in a window of time for the retailer
to exhaust their current supply.

*Collin Cremo, Costco*: It could take 6-8 months for product to cycle
through certain retail stores (smaller local stores).

*Ron Lewis, DOE*: The manufacturer and retailer should determine a
solution should evaluate each situation that arises.

*Greg Murphy, MaxLite*: On the subject of de-listing, suggested when a
model is identified as unqualified, it should automatically come off the
product list. Strongly supports the introduction of additional terms to
designate when a partner voluntary de-lists a product or when they
retire a product -- these items could be marked in blue text and state
'no longer being manufactured' or 'retired'.

*Ed Yandek, GE Lighting*: DOE needs to look at and determine how long a
model stays designated as unqualified on the web site (in red text). The
system should remove unqualified products after a specified period of
time.

*Ron Lewis, DOE*: DOE is looking for ways or further suggestions on
better alternatives to present the specifics of the qualified product
list (i.e. -- qualified, unqualified, retired, etc.).

*Noah Horowitz, NRDC*: PEARL has encountered many times where we test a
model, it fails part of the testing, PEARL contacts the manufacturer,
and finds out that the product is an older version and they have
improved the current product that is out in distribution. Would like to
have a requirement that the manufacturer is required to notify ENERGY
STAR of any and all product changes, especially when a product is
improved. Perhaps manufacturers should be required to submit new and
improved products under a new model number.

*Rich Karney, DOE*: Manufacturers should not be using the same model
number. Manufacturers are required to notify ENERGY STAR each time a
model is changed or upgraded.

*Collin Cremo, Costco*: If product is not up to standard, it should be
out of the marketplace ASAP, and echoed the model number and associated
SKU should no longer be used in the marketplace.

*Demetrios Karambelas, Westinghouse Lighting*: Westinghouse maintains
production lot numbers for their products and most manufacturers do as
well. This helps to verify random failures, product quality, etc. and
differentiate batches of products being manufactured. Manufacturers
could be required to provide this specific information to clarify any
issues and assist in making a better determination on this specific
problem.

*Glenn Reed, NEEP:* Does not want partners to be stuck with
non-qualified products. If a product is de-listed, there should be clear
steps that address the products that are in the distribution and/or
retail pipeline. This is especially important for the national retail
stores, such as the hardware channel, where they have thousands of
stores in many localities.

*Rebecca Foster, CEE*: Stressed that handling a delisting on a
case-by-case basis is not in the best interest of ENERGY STAR. Needs to
develop specifics for partners to follow a set of guidelines when
removing or delisting a product.

[**Effective Date**:]{.underline}

*Ron Lewis, DOE:* Revision suggests the following timeline to direct the
final steps in the criteria revision process, with the effective date of
the final version to go into effect on October 1, 2003.

# Criteria Revision Timeline: 

2^nd^ comments due -- May 16, 2003

DOE reviews comments -- May 31, 2003

3^rd^ and final draft submitted to industry for comment -- June 2, 2003

New Criteria -- October 1, 2003

[**Comments:**]{.underline}

Based on the group's comments, most revolving around scheduling more
time for the 2^nd^ round of comments because of LightFair, the proposed
schedule was revised to the following:

**Criteria Revision Timeline:**

2^nd^ comments due -- May 31, 2003

DOE reviews comments -- June 2, 2003

3^rd^ and final draft submitted to industry for comment -- July 1, 2003

New Criteria -- November 1, 2003