From: Sheri Cleghorn [mailto:CleghornS@energy.wsu.edu] 

Sent: Thursday, January 22, 2009 1:31 PM 

To: Dickie, John 

Subject: EISA 2007 inquiry

Hi John 

The EERE Information Center received an inquiry from a manufacturer about EISA of 2007, 

Section 324 (42USC 6294) on metal halide light fixtures. He would like to know the procedure for 

complying to DOE standards for the circle "E" for metal halide ballasts. He would also like to 

know if they can self declare and put e-markings on the product themselves or is there a testing 

procedure involved. Is this something you are able to respond to? 

Wayne Powell Quality Control Coordinator Antron Compact Electronics LLC 3401 Avenue D Arlington, TX 76011 Phone: 817-701-1400 E-mail: quality@ace-ballast.com 

Thanks, 

Sheri Cleghorn EERE Information Center Office of Energy Efficiency and Renewable Energy (EERE) U.S. Department of Energy www.eere.energy.gov 877-337-3463 

EERE-2008-BT-TP-0017 COMMENT 14
1

MEMORANDUM 

To: Linda Graves 

From: The Metal Halide Lamp Fixtures Rulemaking Team 

Date: February 27, 2009 

Subject: Draft Response to Questions from Wayne Powell, Antron Compact Electronics LLC 

Issue:

Wayne Powell, submitted a question via the DOE EERE Information Center the following question 

regarding EISA Section 324 (Metal Halide Lamp Fixtures) on January 22, 2009: 

Mr. Powell would like to know the procedure for complying to DOE standards for the circle 

"E" lable for metal halide ballasts. He would also like to know if his company can self 

declare and put E-markings on the product or is there a testing procedure involved. 

Context:

Section 324(e) of the Energy Independence and Security Act of 2007 (EISA) amended sections 321 

and 325 of EPCA to add definitions and set energy conservation standards for metal halide lamp 

fixtures that became effective on January 1, 2009. EISA also directed the Federal Trade 

Commission (FTC) to establish labeling requirements of ballasts incorporated into metal halide lamp 

fixtures and packaging of the fixture. 

In the En Masse Technical Amendment Final Rule, DOE will insert the definitions for metal halide 

lamp fixtures into 10 CFR 431.322 and the energy conservation standards into 10 CFR 431.326. 

The FTC completed its labeling rulemaking for metal halide lamp fixtures in 2008. 

The EISA language concerning energy conservation standards for metal halide fixtures can be found 

in Appendix A to this memo. 

Requested DOE Actions:

1. Review and comment / approve the attached response to Wayne Powell of Antron Compact 

Electronics LLC. 

EERE-2008-BT-TP-0017 COMMENT 14
2

Draft Email Response for DOE review:

Dear Mr. Powell, 

Thank you for your email of January 22nd, 2009 concerning the new regulatory standards for Metal 

Halide Lamp Fixtures that took effect on January 1, 2009. You may be aware that Department of 

Energy (DOE) is currently conducting a rulemaking addressing test procedure requirements for 

measuring the performance of ballasts incorporated into metal halide lamp fixtures. Please visit our 

website to review material available on line about this rulemaking 

(http://www1.eere.energy.gov/buildings/appliance_standards/commercial/metal_halide_lamp_ball

asts.html). I will also add you to our interested parties database to make sure you are informed of 

future developments and opportunities to comment on DOE’s proceedings. 

1. How do fixture manufacturers comply with procedures for DOE standards for the circle “E” for 

metal halide ballasts? 

For ballast efficiency measurements, section 324(c) of the Energy Independence and Security Act of 

2007 (EISA) states that “Test procedures for metal halide lamp ballasts shall be based on ANSI 

Standard C82.6–2005, entitled ‘Ballasts for High Intensity Discharge Lamps—Method of 

Measurement’.” DOE is conducting an active rulemaking on this Test Procedure to determine its 

adequacy and accuracy with respect to measurement of metal halide ballast efficiency. Until that 

rulemaking is complete, manufacturers should look to the statute for guidance on the test procedure, 

and in this instance, the statute is relatively clear. 

For ballast efficiency values, section 324(e) of EISA provides the specific efficiency values for the 

various types of covered metal halide ballasts. EISA also establishes certain exclusions from the 

regulation. Please refer to the statute for these levels and exclusions. 

For ballast/package labeling, the Federal Trade Commission (FTC) established requirements for this 

product in 2008. These requirements are contained in two Federal Register notices, 73 FR 39221 

(July 9, 2008) and 73 FR 63066 (October 23, 2008). For your convenience, both of these notices are 

attached to this email. 

2. Can a manufacturer self declare and put E?-markings on the product themselves or is there a 

testing procedure involved? 

As discussed above, DOE is currently developing the test procedure for metal halide lamp ballasts, 

based on ANSI C82.6-2005. The current draft may change based on interested parties comments 

received in response to DOE’s notice of proposed rulemaking (NOPR), so it is uncertain at this 

time whether third-party testing will be required. DOE would welcome your comments on this 

subject, and will notify you as soon as the test procedure NOPR is published and the comment 

period is open. 

Thank you again for your email. I hope my response helps to clarify the issues you raised. We look 

forward to your comments on the forthcoming NOPR. 

Sincerely, 

Linda Graves 

EERE-2008-BT-TP-0017 COMMENT 14
3

Lighting Standards Manager 

Attachments. 

EERE-2008-BT-TP-0017 COMMENT 14
4

Appendix A. EISA 2007 Language on Metal Halide Lamp Fixture Standards 

SEC. 324. METAL HALIDE LAMP FIXTURES 

(a) DEFINITIONS.—Section 321 of the Energy Policy and Conservation Act (42 U.S.C. 6291) (as 

amended by section 322(a)(2)) is amended by adding at the end the following: 

‘‘(58) BALLAST.—The term ‘ballast’ means a device used with an electric discharge lamp to obtain 

necessary circuit 

conditions (voltage, current, and waveform) for starting and operating. 

‘‘(59) BALLAST EFFICIENCY.— 

‘‘(A) IN GENERAL.—The term ‘ballast efficiency’ means, in the case of a high intensity discharge 

fixture, the efficiency of a lamp and ballast combination, expressed as a percentage, and calculated in 

accordance with the following formula: Efficiency = Pout/Pin. 

‘‘(B) EFFICIENCY FORMULA.—For the purpose of subparagraph (A)— 

‘‘(i) Pout shall equal the measured operating lamp wattage; 

 ‘‘(ii) Pin shall equal the measured operating input wattage; 

‘‘(iii) the lamp, and the capacitor when the capacitor is provided, shall constitute a nominal system 

in accordance with the ANSI Standard C78.43–2004; 

‘‘(iv) for ballasts with a frequency of 60 Hz, Pin and Pout shall be measured after lamps have been 

stabilized according to section 4.4 of ANSI Standard C82.6–2005 using a wattmeter with accuracy 

specified 

in section 4.5 of ANSI Standard C82.6–2005; and 

‘‘(v) for ballasts with a frequency greater than 60 Hz, Pin and Pout shall have a basic accuracy of 

±0.5 percent at the higher of— 

‘‘(I) 3 times the output operating frequency of the ballast; or 

‘‘(II) 2 kHz for ballast with a frequency greater than 60 Hz. 

‘‘(C) MODIFICATION.—The Secretary may, by rule, modify the definition of ‘ballast efficiency’ if 

the Secretary determines that the modification is necessary or appropriate to carry out the purposes 

of this Act. 

‘‘(60) ELECTRONIC BALLAST.—The term ‘electronic ballast’means a device that uses 

semiconductors as the primary means to control lamp starting and operation. 

‘‘(61) GENERAL LIGHTING APPLICATION.—The term ‘general lighting application’ means 

lighting that provides an interior or exterior area with overall illumination. 

‘‘(62) METAL HALIDE BALLAST.—The term ‘metal halide ballast’ means a ballast used to start 

and operate metal halide lamps. 

‘‘(63) METAL HALIDE LAMP.—The term ‘metal halide lamp’ means a high intensity discharge 

lamp in which the major portion of the light is produced by radiation of metal halides and their 

products of dissociation, possibly in combination with metallic vapors. 

‘‘(64) METAL HALIDE LAMP FIXTURE.—The term ‘metal halide lamp fixture’ means a light 

fixture for general lighting application designed to be operated with a metal halide lamp and a ballast 

for a metal halide lamp. 

‘‘(65) PROBE-START METAL HALIDE BALLAST.—The term ‘probe-start metal halide ballast’ 

means a ballast that— 

‘‘(A) starts a probe-start metal halide lamp that contains a third starting electrode (probe) in the arc 

tube; and 

‘‘(B) does not generally contain an igniter but instead starts lamps with high ballast open circuit 

voltage. 

‘‘(66) PULSE-START METAL HALIDE BALLAST.— 

EERE-2008-BT-TP-0017 COMMENT 14
5

‘‘(A) IN GENERAL.—The term ‘pulse-start metal halide ballast’ means an electronic or 

electromagnetic ballast that starts a pulse-start metal halide lamp with high voltage pulses. 

‘‘(B) STARTING PROCESS.—For the purpose of subparagraph 

(A)— 

‘‘(i) lamps shall be started by first providing a high voltage pulse for ionization of the gas to produce 

a glow discharge; and 

 ‘‘(ii) to complete the starting process, power shall be provided by the ballast to sustain the discharge 

through the glow-to-arc transition.’’. 

(b) COVERAGE.—Section 322(a) of the Energy Policy and Conservation Act (42 U.S.C. 6292(a)) is 

amended— 

(1) by redesignating paragraph (19) as paragraph (20); and 

(2) by inserting after paragraph (18) the following: ‘‘(19) Metal halide lamp fixtures.’’. 

(c) TEST PROCEDURES.—Section 323(b) of the Energy Policy and Conservation Act (42 U.S.C. 

6293(b)) (as amended by section 301(b)) is amended by adding at the end the following: 

‘‘(18) METAL HALIDE LAMP BALLASTS.—Test procedures for metal halide lamp ballasts shall 

be based on ANSI Standard C82.6–2005, entitled ‘Ballasts for High Intensity Discharge Lamps—

Method of Measurement’.’’. 

(d) LABELING.—Section 324(a)(2) of the Energy Policy and Conservation Act (42 U.S.C. 

6294(a)(2)) is amended— 

(1) by redesignating subparagraphs (C) through (G) as subparagraphs 

(D) through (H), respectively; and 

(2) by inserting after subparagraph (B) the following: 

‘‘(C) METAL HALIDE LAMP FIXTURES.— 

‘‘(i) IN GENERAL.—The Commission shall issue labeling rules under this section applicable to the 

covered 

product specified in section 322(a)(19) and to which standards are applicable under section 325. 

‘‘(ii) LABELING.—The rules shall provide that the labeling of any metal halide lamp fixture 

manufactured 

on or after the later of January 1, 2009, or the date that is 270 days after the date of enactment of 

this 

subparagraph, shall indicate conspicuously, in a manner prescribed by the Commission under 

subsection 

(b) by July 1, 2008, a capital letter ‘E’ printed within a circle on the packaging of the fixture, and 

on the ballast contained in the fixture.’’. 

(e) STANDARDS.—Section 325 of the Energy Policy and Conservation Act (42 U.S.C. 6295) (as 

amended by section 310) is amended— 

(1) by redesignating subsection (hh) as subsection (ii); 

(2) by inserting after subsection (gg) the following: 

‘‘(hh) METAL HALIDE LAMP FIXTURES.— 

‘‘(1) STANDARDS.— 

‘‘(A) IN GENERAL.—Subject to subparagraphs (B) and (C), metal halide lamp fixtures designed to 

be operated with lamps rated greater than or equal to 150 watts but less than or equal to 500 watts 

shall contain— 

‘‘(i) a pulse-start metal halide ballast with a minimum ballast efficiency of 88 percent; 

‘‘(ii) a magnetic probe-start ballast with a minimum ballast efficiency of 94 percent; or 

‘‘(iii) a nonpulse-start electronic ballast with— 

‘‘(I) a minimum ballast efficiency of 92 percent for wattages greater than 250 watts; and 

‘‘(II) a minimum ballast efficiency of 90 percent for wattages less than or equal to 250 watts. 

EERE-2008-BT-TP-0017 COMMENT 14
6

‘‘(B) EXCLUSIONS.—The standards established under subparagraph (A) shall not apply to— 

 ‘‘(i) fixtures with regulated lag ballasts; 

‘‘(ii) fixtures that use electronic ballasts that operate at 480 volts; or 

‘‘(iii) fixtures that— 

‘‘(I) are rated only for 150 watt lamps; 

‘‘(II) are rated for use in wet locations, as specified by the National Electrical Code 2002, section 

410.4(A); and 

‘‘(III) contain a ballast that is rated to operate at ambient air temperatures above 50°C, as specified 

by UL 1029–2001. 

‘‘(C) APPLICATION.—The standards established under subparagraph (A) shall apply to metal 

halide lamp fixtures 

manufactured on or after the later of— 

‘‘(i) January 1, 2009; or 

‘‘(ii) the date that is 270 days after the date of enactment of this subsection. 

‘‘(2) FINAL RULE BY JANUARY 1, 2012.— 

‘‘(A) IN GENERAL.—Not later than January 1, 2012, the Secretary shall publish a final rule to 

determine whether the standards established under paragraph (1) should be amended. 

‘‘(B) ADMINISTRATION.—The final rule shall— 

‘‘(i) contain any amended standard; and 

‘‘(ii) apply to products manufactured on or after January 1, 2015. 

‘‘(3) FINAL RULE BY JANUARY 1, 2019.— 

‘‘(A) IN GENERAL.—Not later than January 1, 2019, the Secretary shall publish a final rule to 

determine 

whether the standards then in effect should be amended. 

‘‘(B) ADMINISTRATION.—The final rule shall— 

‘‘(i) contain any amended standards; and 

‘‘(ii) apply to products manufactured after January 1, 2022. 

‘‘(4) DESIGN AND PERFORMANCE REQUIREMENTS.—Not withstanding any other 

provision of law, any standard established pursuant to this subsection may contain both design and 

performance requirements.’’; and 

(3) in paragraph (2) of subsection (ii) (as redesignated by paragraph (2)), by striking ‘‘(gg)’’ each place 

it appears and inserting ‘‘(hh)’’. 

(f) EFFECT ON OTHER LAW.—Section 327(c) of the Energy Policy and Conservation Act (42 

U.S.C. 6297(c)) is amended— 

(1) in paragraph (8)(B), by striking the period at the end and inserting ‘‘; and’’; and 

(2) by adding at the end the following: 

‘‘(9) is a regulation concerning metal halide lamp fixtures adopted by the California Energy 

Commission on or before January 1, 2011, except that— 

‘‘(A) if the Secretary fails to issue a final rule within 180 days after the deadlines for rulemakings in 

section 

325(hh), notwithstanding any other provision of this section, preemption shall not apply to a 

regulation concerning 

metal halide lamp fixtures adopted by the California Energy Commission— 

 ‘‘(i) on or before July 1, 2015, if the Secretary fails to meet the deadline specified in section 

325(hh)(2); or 

‘‘(ii) on or before July 1, 2022, if the Secretary fails to meet the deadline specified in section 

325(hh)(3).’’. 

EERE-2008-BT-TP-0017 COMMENT 14