CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT 

TABLE OF CONTENTS 

3.1 INTRODUCTION ........................................................................................................... 3-1
 

3.1.1 Definitions............................................................................................................ 3-1
 

3.1.2 Ballast Efficacy Factor......................................................................................... 3-1
 

3.1.3 Fluorescent Lamp................................................................................................. 3-2
 

3.1.4 Fluorescent Lamp Ballast .................................................................................... 3-2
 

3.1.5 Replacement Ballast............................................................................................. 3-4
 

3.2 MARKET ASSESSMENT .............................................................................................. 3-4
 

3.2.1 Trade Associations............................................................................................... 3-4
 

3.2.2 Manufacturers and Market Share......................................................................... 3-5
 

3.2.2.1 Small Businesses...................................................................................... 3-5
 

3.2.3 Regulatory Programs ........................................................................................... 3-2
 

3.2.3.1 Federal Energy Conservation Standards.................................................. 3-2
 

3.2.3.2 California Energy Commission................................................................ 3-5
 

3.2.3.3 Canadian Energy Efficiency Standards ................................................... 3-5
 

3.2.3.4 European Energy Efficiency Standards ................................................... 3-7
 

3.2.4 Non-Regulatory Initiatives................................................................................... 3-7
 

3.2.4.1 Federal Energy Management Program .................................................... 3-7
 

3.2.4.2 Consortium for Energy Efficiency........................................................... 3-8
 

3.2.4.3 NEMA Premium ...................................................................................... 3-9
 

3.2.4.4 ENERGY STAR ...................................................................................... 3-9
 

3.2.4.5 Energy Efficient Commercial Building Deduction.................................. 3-9
 

3.2.4.6 Northeast Energy Efficiency Partnerships............................................. 3-10
 

3.2.5 Historical Shipments.......................................................................................... 3-10
 

3.3 TECHNOLOGY ASSESSMENT.................................................................................. 3-16
 

3.3.1 Basic Structure of Fluorescent Lamps ............................................................... 3-16
 

3.3.2 Electrical Characteristics of a Fluorescent Discharge Lamp ............................. 3-17
 

3.3.3 Fluorescent Lamp Ballast Overview.................................................................. 3-18
 

3.3.3.1 Starting Method ..................................................................................... 3-19
 

3.3.3.2 Ballast Factor ......................................................................................... 3-20
 

3.3.3.3 Ballast Efficacy Factor........................................................................... 3-20
 

3.3.3.4 Power Factor .......................................................................................... 3-20
 

3.3.3.5 Total Harmonic Distortion..................................................................... 3-21
 

3.3.3.6 Electromagnetic Interference ................................................................. 3-21
 

3.3.3.7 Safety ..................................................................................................... 3-22
 

3.3.4 Fluorescent Lamp Ballast Technology Options................................................. 3-22
 

3.3.4.1 Magnetic Ballasts................................................................................... 3-22
 

3.3.4.2 Electronic Ballasts ................................................................................. 3-23
 

3.3.4.3 Lamp Diameter ...................................................................................... 3-27
 

3.3.4.4 Improved Components........................................................................... 3-27
 

3.3.4.5 Improved Circuit Design........................................................................ 3-29
 

3.4 PRODUCT CLASSES................................................................................................... 3-30
 

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EERE-2007-BT-STD-0016 COMMENT 25
3.4.1 Lamp Length...................................................................................................... 3-31
 

3.4.2 Lamp Diameter .................................................................................................. 3-31
 

3.4.3 Ballast Factor ..................................................................................................... 3-32
 

3.4.4 Lumen Package.................................................................................................. 3-32
 

3.4.5 Maximum Number of Lamps Operated............................................................. 3-33
 

3.4.6 Starting Method ................................................................................................. 3-33
 

3.4.7 Input Voltage ..................................................................................................... 3-33
 

3.4.8 Universal Voltage .............................................................................................. 3-34
 

3.4.9 Residential Ballasts............................................................................................ 3-34
 

3.4.10 Sign Ballasts....................................................................................................... 3-34
 

3.4.11 Product Classes .................................................................................................. 3-35
 

REFERENCES .......................................................................................................................... 3-36
 

LIST OF TABLES 

Table 3.2.1 EPCA Standards for Fluorescent Lamp Ballasts ...................................................... 3-2
 

Table 3.2.8 Shipments of Four-Foot T8 MBP and Two-Foot T8 U-Shaped Ballasts and Lamps 

Table 3.2.9 Shipments of Eight-Foot Slimline T8 and Eight-Foot SP Slimline T12 Ballasts and 

Table 3.3.2 Basic Building Blocks of a Fixed-Light Output Fluorescent Lamp Ballast and 

Table 3.4.1 EPCA Product Classes Established by NAECA 1988 for Fluorescent Lamp Ballasts
 

Table 3.4.2 EPCA Product Classes Established by EPACT 2005 for Fluorescent Lamp Ballasts3­

Table 3.2.2 2000 Ballast Rule Standards for Fluorescent Lamp Ballasts.................................... 3-3
 

Table 3.2.3 EPACT 2005 Standards for Fluorescent Lamp Ballasts........................................... 3-4
 

Table 3.2.4 Canadian Standards for Fluorescent Lamp Ballasts ................................................. 3-6
 

Table 3.2.5 Federal Energy Management Program Efficiency Recommendation ...................... 3-8
 

Table 3.2.6 CEE High-Performance T8 Ballast Specifications................................................... 3-8
 

Table 3.2.7 CEE Reduced Wattage T8 Ballast Specifications .................................................... 3-9
 

and Four-Foot T12 MBP and Two-Foot U-Shaped Ballasts and Lamps................................... 3-13
 

Lamps......................................................................................................................................... 3-14
 

Table 3.2.10 T12 High-Output Ballast Market Share................................................................ 3-15
 

Table 3.3.1 Common Linear Fluorescent Lamp Nomenclature ................................................ 3-17
 

Associated Characteristics ......................................................................................................... 3-25
 

.................................................................................................................................................... 3-30
 

30
 

Table 3.4.3 Preliminary Product Classes for Fluorescent Lamp Ballasts.................................. 3-35
 

LIST OF FIGURES 

Figure 3.2.1 2005 Ballast Market Share .................................................................................... 3-11
 

Figure 3.2.2 Magnetic and Electronic Ballast Market Share ..................................................... 3-12
 

Figure 3.2.3 Shipments of Ballasts that Operate Four-Foot MBP Lamps................................. 3-13
 

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EERE-2007-BT-STD-0016 COMMENT 25
Figure 3.2.4 Shipments of Eight-Foot Slimline T8 and Eight-Foot SP Slimline T12 Ballasts . 3-14
 

Figure 3.2.5 Shipments of Residential Ballasts ......................................................................... 3-15
 

Figure 3.2.6 Shipments of T5 High-Output Ballasts ................................................................. 3-16
 

Figure 3.3.1 Electrical Characteristic of a Gas Discharge Lamp............................................... 3-18
 

Figure 3.3.2 Cutaway View of a Typical Magnetic Fluorescent Ballast................................... 3-23
 

Figure 3.3.3 Fluorescent Lamp Efficacy vs. Operating Frequency of Lamp ............................ 3-24
 

Figure 3.3.4 Cutaway View of an Electronic Fluorescent Ballast............................................. 3-24
 

Figure 3.3.5 Fixed-Light Output Electronic Fluorescent Ballast Block Diagram ..................... 3-25
 

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EERE-2007-BT-STD-0016 COMMENT 25
 

CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT 

3.1 INTRODUCTION 

This chapter details the market and technology assessment that the U.S. Department of 

Energy (DOE) has conducted in support of the ongoing energy conservation standards and test 

procedure rulemakings for fluorescent lamp ballasts. These rulemakings are mandated by the 

Energy Policy and Conservation Act (EPCA), as amended, and are effective for ballasts 

manufactured during and after 2014. 

This chapter consists of three sections: the market assessment, the technology 

assessment, and product classes. The market assessment provides an overall picture of the 

market for the products concerned, including the nature of the products, industry structure, and 

manufacturer market shares; regulatory and non-regulatory efficiency improvement programs; 

and market trends and quantities of products sold. The technology assessment identifies a 

preliminary list of technologies to consider in the screening analysis. The product classes section 

discusses the product classes DOE considered using for this rulemaking and how they were 

developed. 

The information DOE gathers from the market and technology assessment serves as 

resource material for use throughout the rulemaking. DOE considers both quantitative and 

qualitative information from publicly available sources and interested parties. 

3.1.1 Definitions 

Section 321 of EPCA contains definitions for fluorescent lamp ballast and associated 

terms. DOE codified in the Code of Federal Regulations (CFR) the statutory definitions and 

definitions of supplementary terms for fluorescent lamp ballasts in 10 CFR 430.2. Appendix 3A 

lists these terms and their definitions. 

As part of this energy conservation standards rulemaking, DOE is considering extending 

coverage to additional fluorescent lamp ballasts. (42 U.S.C. 6295(g)(7)(B)) The following 

sections describe in more detail the definitions in EPCA for fluorescent lamp ballasts and note 

DOE’s interpretation of the definitions. Please see chapter 2 of this preliminary technical support 

document (TSD) for more discussion on DOE’s consideration of additional fluorescent lamp 

ballasts and its interpretation of EPCA’s definitions. 

3.1.2 Ballast Efficacy Factor 

Section 321(30)(A) of EPCA (42 U.S.C. 6291(30)(A)) defines ballast efficacy factor 

(BEF) as: 

Ballast efficacy factor means the relative light output divided by the power input of a 

fluorescent lamp ballast, as measured under test conditions specified in ANSI Standard 

C82.2–1984. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

DOE is conducting concurrent rulemakings for an active mode test procedure and a 

standby mode test procedure for fluorescent lamp ballasts. Information on these rulemakings can 

be found on DOE’s website.a

 The test procedures specify how manufacturers measure and 

calculate ballast efficacy factor. 

3.1.3 Fluorescent Lamp 

Section 321(30)(A) of EPCA (42 U.S.C. 6291(30)(A)) defines a fluorescent lamp: 

Fluorescent lamp means a low pressure mercury electric-discharge source in which a 

fluorescing coating transforms some of the ultraviolet energy generated by the mercury 

discharge into light, including only the following: 

(1) any straight-shaped lamp (commonly referred to as 4-foot medium bipin lamps) 

with medium bipin bases of nominal overall length of 48 inches and rated wattage 

of 25 or more; 

(2) any U-shaped lamp (commonly referred to as 2-foot U-shaped lamps) with 

medium bipin bases of nominal overall length between 22 and 25 inches and rated 

wattage of 25 or more; 

(3) any rapid start lamp (commonly referred to as 8-foot high output lamps) with 

recessed double contact (RDC) bases of nominal overall length of 96 inches; 

(4) any instant start lamp (commonly referred to as 8-foot slimline lamps) with single 

pin bases of nominal overall length of 96 inches and rated wattage of 52 or more; 

(5) any straight-shaped lamp (commonly referred to as 4-foot miniature bipin 

standard output lamps) with miniature bipin bases of nominal overall length 

between 45 and 48 inches and rated wattage of 26 or more; and 

(6) any straight-shaped lamp (commonly referred to 4-foot miniature bipin high 

output lamps) with miniature bipin bases of nominal overall length between 45 

and 48 inches and rated wattage of 49 or more. 

This definition, codified at 10 CFR 430.2, reflects the version adopted in the final rule for 

general service fluorescent lamps (the 2009 Lamps Rule).b

 74 FR 34080, 34176-77 (July 14, 

2009). 

3.1.4 Fluorescent Lamp Ballast 

Fluorescent lamp ballast means a device that is used to start and operate fluorescent 

lamps by providing a starting voltage and current and limiting the current during normal 

operation. 

a

 DOE’s website for fluorescent lamp ballasts can be found at 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballasts.html. b

 The 2009 Lamps Rule was published in the Federal Register on July 14, 2009 and is available at 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps.html 

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EERE-2007-BT-STD-0016 COMMENT 25
 

As part of this rulemaking, under the authority of 42 U.S.C. 6295(i)(5), DOE is considering 

extending coverage to additional fluorescent lamp ballasts. In chapter 2 of the preliminary TSD, 

DOE considers extending energy conservation standards coverage to the following list of 

fluorescent lamp ballasts: 

(1) ballasts that operate one, two, three, four, five, or six straight-shaped lamps 

(commonly referred to as 4-foot medium bipin lamps) with medium bipin bases, a 

nominal overall length of 48 inches, a rated wattagec

 of 25 watts (W) or more, and 

an input voltage at or between 120 volts (V) and 277V; 

(2) ballasts that operate one, two, three, four, five, or six U-shaped lamps (commonly 

referred to as 2-foot U-shaped lamps) with medium bipin bases, a nominal overall 

length between 22 and 25 inches, a rated wattage of 25W or more, and an input 

voltage at or between 120V and 277V; 

(3) ballasts that operate one or two rapid start lamps (commonly referred to as 8-foot 

high output lamps) with recessed double contact bases, a nominal overall length 

of 96 inches and an input voltage at or between 120V and 277V; 

(4) ballasts that operate one or two instant start lamps (commonly referred to as 8­

foot slimline lamps) with single pin bases, a nominal overall length of 96 inches, a 

rated wattage of 52W or more, and an input voltage at or between 120V and 

277V; 

(5) ballasts that operate one or two straight-shaped lamps (commonly referred to as 4­

foot miniature bipin standard output lamps) with miniature bipin bases, a nominal 

length between 45 and 48 inches, a rated wattage of 26W or more, and an input 

voltage at or between 120V and 277V; 

(6) ballasts that operate one, two, three, or four straight-shaped lamps (4-foot 

miniature bipin high output lamps) with miniature bipin bases, a nominal length 

between 45 and 48 inches, a rated wattage of 49W or more, and an input voltage 

at or between 120V and 277V; 

(7) ballasts that operate one, two, three, or four straight-shaped lamps (commonly 

referred to as 4-foot medium bipin lamps) with medium bipin bases, a nominal 

overall length of 48 inches, a rated wattage of 25W or more, an input voltage at or 

between 120V and 277V, a power factor (PF) of less than 0.90, and that are 

designed and labeled for use in residential applications; and 

(8) ballasts that operate one, two, three, four, five, or six rapid start lamps (commonly 

referred to as 8-foot high output lamps) with recessed double contact bases, a 

nominal overall length of 96 inches, an input voltage at or between 120V and 

277V, and that operate at ambient temperatures of 20 °F or less and are used in 

outdoor signs. 

DOE is considering exempting the following ballasts: 

(1) ballasts designed for dimming to 50 percent or less of the maximum output of the 

ballasts. 

c

 The 2009 Lamps Rule adopted a new definition for rated wattage that can be found in 10 CFR 430.2. 

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3.1.5 Replacement Ballast 

Replacement ballast means a ballast that 

(1) is designed for use to replace an existing fluorescent lamp ballast in a previously 

installed luminaire; 

(2) is marked “FOR REPLACEMENT USE ONLY”; 

(3) is shipped by the manufacturer in packages containing not more than 10 

fluorescent lamp ballasts; and 

(4) has output leads that when fully extended are a total length that is less than the 

length of the lamp with which the ballast is intended to be operated. 

3.2 MARKET ASSESSMENT 

The following market assessment identifies the manufacturer trade association and 

domestic manufacturers of fluorescent lamp ballasts; discusses manufacturer market share, 

regulatory programs, and non-regulatory initiatives; defines product classes; provides historical 

shipment data, shipment projections, and equipment lifetime estimates; and summarizes market 

performance data. 

3.2.1 Trade Associations 

The National Electrical Manufacturers Association (NEMA) is the trade association for 

fluorescent lamp ballasts. NEMA’s Lighting Systems Division is one of eight product divisions. 

The division’s 47 member companies comprise 85-95 percent of the U.S. commercial and 

industrial market, as well as large portions of the institutional and educational markets.1

 In 

addition to ballasts, NEMA’s Lighting Systems Division also oversees products such as 

fluorescent lamps, emergency lighting, lighting controls, luminaires, solid state lighting, and 

other emerging lighting technologies. NEMA provides an organization through which 

manufacturers of lighting equipment can work together on projects that affect their industry and 

business. NEMA’s activities relating to energy efficiency include2 

•	 “[a]dvising the DOE and executive agencies on lighting research and market
 

transformation needs; 

•	 engaging in legislative work on energy and lighting issues; 

•	 monitoring energy-efficiency rulemakings and standards affecting lighting products by 

federal and state agencies; 

•	 promoting the national voluntary luminaire rating and information program under the 

National Lighting Collaborative; 

•	 supporting adoption of 1999 ASHRAE/IESNA 90.1 lighting provisions; 

•	 working with market transformation and environmental groups to advance market use of 

energy-efficient lighting technologies; 

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EERE-2007-BT-STD-0016 COMMENT 25
•	 advising DOE and the U.S. Environmental Protection Agency (EPA) on ENERGY STAR 

Buildings and ENERGY STAR voluntary product labeling programs; and 

•	 advocating market-based approaches to enhance the use and penetration of energyefficient technologies.” 

3.2.2 Manufacturers and Market Share 

The following list contains the names of manufacturers that produce fluorescent lamp ballasts: 

• 

• 

• 

Acuity Brands 

Lighting 

Advance Transformer 

American Ballast 

• 

• 

General Electric 

Consumer & 

Industrial 

Hatch Transformer 

• 

• 

• 

• 

PQL 

Prescolite 

Progress Lighting 

Radionic 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Antron Compact 

Electronics 

Axis Technologies 

Ballast Wise 

Bodine 

CEW 

Cooper Lighting 

EBW Electronics 

Espen Technology, 

Inc. 

Etlin-Daniels 

Fulham 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Holophane 

Howard Industries 

Iota Engineering 

Keystone 

Technologies 

Lamar Lighting 

SOLA Ballasts 

Lighting Components 

Lightolier 

Lutron Electronics 

Company, Inc. 

MaxLite 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Robertson Worldwide 

Sage Lighting Ltd. 

SLI Lighting 

Sunpark Electronics 

Corp. 

Superior Lamps, Inc. 

TCP 

Ultrasave Lighting 

Ltd. 

Universal Lighting 

Technologies 

Ventex 

• France • 

• 

OSRAM Sylvania 

Pacific Lighting and 

Electric 

• 

• 

Venture Lighting 

International 

Wide-Lite 

Four manufacturers hold the majority of the domestic market share of fluorescent lamp ballasts 

•	 GE Consumer and Industrial of General Electric, Inc. (hereafter, “GE”) 

•	 OSRAM Sylvania of Siemens AG (hereafter “Osram Sylvania”) 

•	 Advance Transformer of Philips Lighting (hereafter “Advance”) 

•	 Universal Lighting Technologies (hereafter “Universal”). 

The lighting divisions of some of these companies also manufacture other products, such 

as fluorescent lamps, high intensity discharge lamps, light emitting diodes (LEDs), and compact 

fluorescent lamps (CFLs). 

3.2.2.1 Small Businesses 

Small businesses may be particularly affected by the promulgation of minimum energy 

conservation standards for fluorescent lamp ballasts. The Small Business Administration (SBA) 

lists small business size standards that are matched to industries as they are described in the 

North American Industry Classification System (NAICS). A size standard is the largest that a 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

for-profit concern can be and still qualify as a small business for Federal Government programs. 

These size standards are generally the average annual receipts or the average employment of a 

firm. For fluorescent lamp ballasts, the size standard is matched to NAICS code 335311, Power, 

Distribution, & Specialty Transformer Manufacturing, which has a size standard of 750 

employees or fewer.3 

DOE will study the potential impacts on these small businesses in detail during the 

manufacturer impact analysis, which it will conduct as part of the notice of proposed rulemaking. 

3.2.3 Regulatory Programs 

Several Federal and international regulatory programs affect the markets for fluorescent 

lamp ballasts. The following section summarizes U.S., Canadian, and European regulatory 

initiatives relevant to the ballasts covered by this rulemaking. While the following discussion is 

not exhaustive in describing all regulatory action related to fluorescent lamp ballasts, it provides 

detail on some notable initiatives that characterize recent developments in the lighting market. 

3.2.3.1 Federal Energy Conservation Standards 

EPCA (42 U.S.C. 6291–6309) established an energy conservation program for major 

household appliances. Additional amendments to EPCA gave DOE the authority to regulate the 

energy efficiency of several products, including certain fluorescent lamp ballasts. Amendments 

to EPCA in the National Appliance Energy Conservation Amendments of 1988 (NAECA 1988), 

Pub. L.100357, established energy conservation standards for fluorescent lamp ballasts.d

 (42 

U.S.C. 6295(g)(5)) The standards promulgated by NAECA 1988 can be found in Table 3.2.1. 

These amendments also required that DOE (1) conduct two rulemaking cycles to determine 

whether these standards should be amended; and (2) for each rulemaking cycle, determine 

whether the standards in effect for fluorescent lamp ballasts should be amended so that they 

would be applicable to additional fluorescent lamp ballasts. (42 U.S.C. 6295(g)(7)(A)(B)) 

Table 3.2.1 EPCA Standards for Fluorescent Lamp Ballasts 

d

 Although fluorescent lamp ballasts are typically understood to be used in the commercial and industrial sectors, it 

is the “consumer products” section of the statute that grants authority to DOE to cover and regulate this product. In 

the United States Code, Title 42 “The Public Health and Welfare,” chapter 77, “Energy Conservation,” subchapter 

III, “Improving Energy Efficiency,” two parts cluster the group of products DOE regulates. “Part A – Energy 

Conservation Program for Consumer Products Other than Automobiles” includes a range of consumer products, 

some which may be classified as being used primarily in the residential sector, such as refrigerators, dishwashers, 

and clothes washers. However, Part A also includes consumer products that might also be used primarily in the 

commercial sector, such as fluorescent lamps, fluorescent lamp ballasts, and urinals. Second, subchapter III has 

“Part A1– Certain Industrial Equipment,” which includes products that are primarily used in the commercial and 

industrial sectors, such as electric motors and pumps, and packaged terminal air conditioners and heat pumps. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

Application for Operation of 

Ballast Input 

Voltage 

V 

Total Nominal 

Lamp Watts 

W 

Ballast Efficacy 

Factor 

One F40T12 Lamp 120 40 1.805 

277 40 1.805 

Two F40T12 Lamps 120 80 1.060 

277 80 1.050 

Two F96T12 Lamps 120 150 0.570 

277 150 0.570 

Two F96 T12 High Output 120 220 0.390 

(HO) Lamps 277 220 0.390 

On September 19, 2000, DOE published a final rule in the Federal Register that 

completed the first of the two rulemaking cycles to evaluate and amend the energy conservation 

standards for fluorescent lamp ballasts (hereafter “the 2000 Ballast Rule”). 65 FR 56740. This 

rulemaking established a consensus standard, representing an agreement between the fluorescent 

lamp ballast industry and energy-efficiency advocacy organizations. The standard levels DOE 

adopted replaced the ballast efficacy factors promulgated in NAECA 1988 for certain fluorescent 

lamp ballasts. The standard levels were intended to eliminate certain magnetic ballasts, which 

operate lamps at a line frequency of 60 Hertz (Hz), and are less efficient than electronic ballasts, 

which operate lamps at high frequency for ballasts that operate F40T12 and F96T12 lamps.e 

Table 3.2.2 shows the standards codified by DOE. 10 CFR 430.32(m)(3) 

Table 3.2.2 2000 Ballast Rule Standards for Fluorescent Lamp Ballasts 

Application for Operation of 

Ballast Input 

Voltage 

V 

Total Nominal 

Lamp Watts 

W 

Ballast Efficacy 

Factor 

One F40T12 Lamp 120 40 2.29 

277 40 2.29 

Two F40T12 Lamps 120 80 1.17 

277 80 1.17 

Two F96T12 Lamps 120 150 0.63 

277 150 0.63 

Two F96 T12 HO Lamps 120 220 0.39 

277 220 0.39 

Due to the language in the consensus standard that DOE adopted in the 2000 Ballast 

Rule, it was still be possible for manufacturers to produce and sell magnetic ballasts for certain 

types of fluorescent lamps. In response, Congress promulgated new energy conservation 

standards for certain fluorescent lamp ballasts under the Energy Policy Act of 2005 (EPACT 

2005), Pub. L. 10958. (EPACT section 135(c)(2); codified at 42 U.S.C. 6295(g)(8)(A)). On 

October 18, 2005, DOE published a final rule in the Federal Register codifying those new 

fluorescent lamp ballast standards into the Code of Federal Regulations at 10 CFR 430.32(m). 70 

FR 60407. These standards established minimum ballast efficacy requirements for “energy 

e

 The standard level was intended to eliminate magnetic ballasts that operate one and two nominally 40W medium 

bipin lamps (F40T12) and two nominally 75W 8-foot T12 single pin slimline lamps (F96T12). 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

saver” versions of full-wattage ballasts, such as the F34T12 ballast. Table 3.2.3 shows the 

standards prescribed by EPACT 2005. 10 CFR 430.32(m)(5) 

Table 3.2.3 EPACT 2005 Standards for Fluorescent Lamp Ballasts 

Application for Operation of 

Ballast Input 

Voltage 

V 

Total Nominal 

Lamp Watts 

W 

Ballast Efficacy 

Factor 

One F34T12 Lamp 120 34 2.61 

277 34 2.61 

Two F34T12 Lamps 120 68 1.35 

277 68 1.35 

Two F96T12/ES Lamps 120 120 0.77 

277 120 0.77 

Two F96 T12 HO/ES Lamps 120 190 0.42 

277 190 0.42 

In summary, fluorescent lamp ballasts that are currently regulated under EPCA, as 

amended, include ballasts that are designed to operate one and two nominally 40W and 34W 4­

foot T12 medium bipin lamps (F40T12 and F34T12), two nominally 75W and 60W 8-foot T12 

single pin slimline lamps (F96T12 and F96T12/ES), and two nominally 110W and 95W 8-foot 

T12 RDC high output lamps (F96T12 and F96T12/ES) at nominal input voltages of 120 or 277 

volts with an input current frequency of 60 Hz and a power factor of 0.90 or greater. 10 CFR 

430.32(m). Ballasts that are excluded from regulation include (1) ballasts designed for dimming 

to 50 percent or less of its maximum output, (2) ballasts designed for use with two F96T12 high 

output (HO) lamps at ambient temperatures of 20 °F or less and for use in an outdoor sign or 

ballasts designed for use with two F96T12 HO/ES lamps at ambient temperatures of 20 °F or 

less and for use in an outdoor sign,f (3) ballasts with a power factor of less than 0.90 and 

designed and labeled for use only in residential building applications, and (4) replacement 

ballasts as defined in paragraph (m)(4)(ii).g 10 CFR 430.32(m)(2), (m)(4), and (m)(7). 

On December 19, 2007, the President signed the Energy Independence and Security Act 

of 2007 (EISA 2007) (Pub. L. 110140), which makes numerous amendments to EPCA and 

directs DOE to undertake several new rulemakings for appliance energy efficiency standards. 

EISA 2007 did not amend standards for fluorescent lamp ballasts, but instead directed DOE to 

amend its test procedure for fluorescent lamp ballasts to incorporate a measure of standby mode 

and off mode energy consumption by March 31, 2009. (42 U.S.C. 6295(gg)(2)(B)(ii)) In 

addition, pursuant to 42 U.S.C. 6295(o), DOE is directed to incorporate standby mode and off 

f

 In 10 CFR 430.32(m)(7), the temperature exemption granted under EPACT 2005 is slightly different than that 

contained in sections (m)(2) and (m)(4). In subsection (m)(7), ballasts designed for use with two F96T12HO/ES 

lamps at ambient temperatures “of 20°F or less” and designated for use in an outdoor sign are exempt from the 

standards in paragraph (m)(5). The other sections require the ballast to be for ambient temperatures of negative 20°F 

or less. 

g

 The exclusion provided for replacement ballasts requires that they meet certain criteria to be considered a 

replacement ballast, such as being designed to replace an existing ballast in a previously installed luminaire and 

being marked “FOR REPLACEMENT USE ONLY.” This exclusion only applies to replacement ballasts 

manufactured on or before June 30, 2010. After that date, replacement ballasts will no longer be excluded. (10 CFR 

430.32(m)(4)(ii)(A)) See appendix A of this TSD for the exact language of the exclusion for replacement ballasts. 

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mode energy use in any amended or new standard adopted after July 1, 2010. Because this 

energy conservation standards rulemaking for fluorescent lamp ballasts will be completed in 

2011, the requirement to incorporate standby mode energy use into the energy conservation 

standards analysis is applicable. 

DOE published a final rule test procedure to comply with the standby mode and off mode 

energy use provisions from EISA 2007 that apply to fluorescent lamp ballasts that are (or could 

be) covered by this rulemaking. DOE stated in that final rule that standby mode energy use, as 

defined in EISA 2007,h

 is nonexistent for typical ballasts that operate on a switch or a motion 

sensor. DOE also stated that standby mode energy use is only applicable to ballasts with a 

lighting control system. One example of these new ballast designs is a DALIi-enabled ballast. 

DALI-enabled ballasts exhibit standby power, as they have internal circuitry that is integral to 

the design of the ballast that remains on and active, even when the ballast is not driving any 

lamps. DOE noted that fluorescent lamp ballasts never meet the definition of “off mode.” 

Pursuant to EPCA section 325(gg)(2)(A), 42 U.S.C. 6295(gg)(2)(A), DOE is evaluating 

whether to incorporate standby mode into a single amended or new metric. DOE is also 

evaluating whether to include standby mode standards in this rulemaking. For more information, 

see chapter 2 of the preliminary TSD. 

3.2.3.2 California Energy Commission 

The California Energy Commission (CEC) specifies appliance standards that are 

“applicable as state law to the sale and offering for sale of appliances in California.”4 The current 

standards took effect on December 29, 2007. The CEC is currently undergoing a rulemaking to 

revise the existing standards. 

3.2.3.3 Canadian Energy Efficiency Standards 

The Natural Resources Canada (NRCan) Office of Energy Efficiency regulates the 

energy efficiency of fluorescent lamp ballasts in Canada. In 1992, Parliament passed the Energy 

Efficiency Act (S.C. 1992, c. 36), which concerns minimum performance levels for energy-using 

products, effective in February 1995. Fluorescent lamp ballasts were included in the first set of 

energy efficiency regulations, published in November 1994.5

 An amendment published in April 

2003 updated Canada’s regulations to the minimum levels put forth in the 2000 Ballast Rule. It 

h

 In amending 42 U.S.C. 6295(gg)(1)(a)(i), (ii), and (iii), section 310 of EISA 2007 defines “active mode,” “off 

mode,” and “standby mode” as follows: “The term ‘active mode’ means the condition in which an energy-using 

product—(I) is connected to a main power source; (II) has been activated; and (III) provides 1 or more main 

functions.” “The term ‘off mode’ means the condition in which an energy-using product— (I) is connected to a main 

power source; and (II) is not providing any standby or active mode function.” “The term ‘standby mode’ means the 

condition in which an energy-using product (I) is connected to a main power source; and (II) offers 1 or more of the 

following user-oriented or protective functions: (aa) To facilitate the activation or deactivation of other functions 

(including active mode) by remote switch (including remote control), internal sensor, or timer. (bb) Continuous 

functions including information or status displays (including clocks) or sensor-based functions.”

i

 DALI stands for Digital Addressable Lighting Interface, which is a system that enables communication between a 

central lighting controls system and the individual components, including the ballasts. 

3-5 

EERE-2007-BT-STD-0016 COMMENT 25
 

also proposed two effective dates: April 1, 2005 for new installations and April 1, 2010 for 

existing installations (replacement ballasts).6

 Amendment 9, published in the Canadian Gazette 

Part II on November 15, 2006, introduced standards for ballasts that operate energy-saving lamps 

and F32T8 lamps, modified the criteria for exempted ballasts, and repealed the effective date for 

fluorescent lamp ballasts.7

 Table 3.2.48 shows the current Canadian standards for fluorescent 

lamp ballasts. 

Table 3.2.4 Canadian Standards for Fluorescent Lamp Ballasts 

Application for Operation of 

Ballast Input 

Voltage 

V 

Total Nominal 

Lamp Wattage | 

W 

Minimum Ballast Efficacy Factor 

Level 1j

 Level 2k 

One F40T12 Lamp* 

120 40 1.805 2.29 

277 40 1.805 2.29 

347 40 1.750 2.22 

One F34T12 Lamp 

120 34 1.805 2.61 

277 34 1.805 2.61 

347 34 1.750 2.53 

Two F40T12 Lamps 

120 80 1.060 1.17 

277 80 1.050 1.17 

347 80 1.020 1.12 

Two F34T12 Lamps 

120 68 1.060 1.35 

277 68 1.050 1.35 

347 68 1.020 1.29 

Two F96T12(IS) Lamps** 

120 150 0.570 0.63 

277 150 0.570 0.63 

347 150 0.530 0.62 

Two F96T12(ES) Lamps 

120 120 0.570 0.77 

277 120 0.570 0.77 

347 120 0.530 0.76 

Two 110W F96T12 HO Lamps 

120 220 0.390 0.390 

277 220 0.390 0.390 

347 220 0.380 0.380 

Two F96T12 HO(ES) Lamps 

120 190 0.390 0.42 

277 190 0.390 0.42 

347 190 0.380 0.41 

Two F32T8 Lamps 

120 64 1.250 1.250 

277 64 1.230 1.230 

347 64 1.200 1.200 

*Also for use on 40W/48T10/RS lamps 

**Also for use on 60W/96T12/IS lamps 

The Canadian standards listed above apply to residential as well as commercial ballasts. 

Canadian standards consider an input voltage of 347V in addition to 120V and 277V, which is 

consistent with the Canadian electrical distribution network. Canadian standards also require a 

j

 The Level 1 effective date is April 1, 2005 for replacement ballasts.
 k

 The Level 2 effective date for new installation ballasts is February 3, 1995; the Level 2 effective date for 

replacement ballasts is April 1, 2010. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

minimum power factor of 0.9 (consistent with U.S. standards) for all ballasts except residential 

ballasts. 

3.2.3.4 European Energy Efficiency Standards 

Directive 2005/32/EC of the European Parliament and the Council of the European Union 

amended Council Directive 92/42/EEC and Directives 96/57/EC and 2000/55/EC to establish a 

framework for setting energy efficiency requirements for energy-using products. Energy 

efficiency standards for fluorescent lamp ballasts have yet to be published. 

3.2.4 Non-Regulatory Initiatives 

DOE reviewed several national, regional, and local voluntary programs that promote the 

use of energy efficient lighting in the United States. These include the Federal Energy 

Management Program’s (FEMP’s) program for energy efficient lighting, the Consortium for 

Energy Efficiency’s (CEE’s) High Performance Commercial Lighting Initiative, the ENERGY 

STAR Program, and the Northeast Energy Efficiency Partnership (NEEP). The following section 

summarizes some of these programs for the ballasts covered by this rulemaking. While it is not 

an exhaustive list, the discussion provides detail on some notable initiatives that characterize 

recent developments in the lighting market. 

3.2.4.1 Federal Energy Management Program 

FEMP helps Federal buyers identify and purchase energy efficient products including 

certain fluorescent ballasts. Section 161 of EPACT 1992 encourages energy efficient Federal 

procurement. Section 104 of EPACT 2005 requires that each agency incorporate energy 

efficiency criteria consistent with ENERGY STAR and FEMP-designated products for “...all 

procurements involving energy consuming products and systems, including guides 

specifications, project specifications, and construction, renovation, and service contracts that 

include provision of energy consuming products and systems, and into the factors for the 

evaluation of offers received for the procurement.” Executive Order 13123 and Federal 

Acquisition Regulation (FAR) section 23.704 direct agencies to purchase products in the upper 

25 percent of energy efficiency, including all models that qualify for the ENERGY STAR 

product labeling program. 64 FR 30851, 30854 (June 8, 1999). FEMP provides 

recommendations for how to buy energy efficient fluorescent ballasts, including the products 

shown in Table 3.2.5.9

 FEMP offers buyers support tools such as efficiency guidelines, costeffectiveness examples, and a cost calculator. FEMP also offers training, on-site audits, 

demonstrations, and design assistance. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

Table 3.2.5 Federal Energy Management Program Efficiency Recommendation 

Lamp Type Number of 

Lamps Recommended BEF Best Available BEF 

Four-Foot and U-Tube Lamps 

T8, 32 Watts 

1 2.54 or higher 3.00 

2 1.44 or higher 1.54 

3 0.93 or higher 1.06 

4 0.73 or higher 0.79 

T12, 34 Watts 

1 2.64 or higher 3.05 

2 1.41 or higher 1.53 

3 0.93 or higher 0.95 

Eight-Foot Lamps 

T8, 59 Watts 2 0.80 or higher 0.81 

T12, 60 Watts 2 0.80 or higher 0.80 

3.2.4.2 Consortium for Energy Efficiency 

CEE has both a Residential Lighting Initiative and a High-Performance Commercial 

Lighting Initiative. CEE launched its commercial lighting initiative in November 2004 to help 

identify and select energy efficient commercial lighting products and practices. Initial efforts 

focused on designating high-performance T8 lighting products. In January 2007, the initiative 

was expanded to include reduced-wattage T8 products. Table 3.2.6 and Table 3.2.7 summarize 

CEE’s specifications for high-performance and reduced-wattage T8 ballasts. 

Table 3.2.6 CEE High-Performance T8 Ballast Specifications10 

Instant Start Ballast 

Lamps Low BF 

BF≤ 0.85 

Normal BF 

0.85<BF<1.0 

High BF 

BF≥1.01 

1 ≥ 3.08 ≥ 3.11 n/a 

2 ≥ 1.60 ≥ 1.58 ≥ 1.55 

3 ≥ 1.04 ≥ 1.05 ≥ 1.04 

4 ≥ 0.79 ≥ 0.80 ≥ 0.77 

Programmed Rapid Start Ballast 

1 ≥ 2.84 ≥ 2.84 n/a 

2 ≥ 1.48 ≥ 1.47 ≥ 1.51 

3 ≥ 0.97 ≥ 1.00 ≥ 1.00 

4 ≥ 0.76 ≥ 0.75 ≥ 0.75 

Ballast Frequency 20 to 33 kHz or ≥ 40 kHz, Power Factor ≥ 0.90, Total Harmonic Distortion ≤

20% 

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EERE-2007-BT-STD-0016 COMMENT 25
 

Table 3.2.7 CEE Reduced Wattage T8 Ballast Specifications11 

Instant Start Ballast, 28W Systems 

Lamps All BF Ranges 

1 ≥ 3.52 

2 ≥ 1.76 

3 ≥ 1.16 

4 ≥ 0.88 

Instant Start Ballast, 25W Systems 

1 ≥ 3.95 

2 ≥ 1.98 

3 ≥ 1.32 

4 ≥ 0.99 

Ballast Frequency 20 to 33 kHz or ≥ 40 kHz, Power Factor ≥ 0.90, Total 

Harmonic Distortion ≤ 20% 

CEE created separate standards for normal wattage T8 ballasts based on ballast factor, 

which compares the ratio of light output of lamps operated by a specific ballast to the light 

output of the same lamps operated by a standard reference ballast. However, CEE chose not to 

create standards by ballast factor for reduced-wattage ballasts. Additionally, CEE did not specify 

performance based on input voltage. CEE’s specifications state that multi-voltage ballasts must 

meet or exceed the listed BEF when operating on at least one of the intended operating voltages. 

3.2.4.3 NEMA Premium 

NEMA maintains a labeling program for “NEMA Premium” ballasts based on CEE’s 

specifications for high-efficiency 4-foot T8 ballasts. The program is intended to promote energy 

efficiency and assist end-users in identifying the most efficient ballasts on the market.12 As of 

March 2009, NEMA’s website indicates that ballasts manufactured by Acuity Brands Lighting, 

Advance, American Ballast, Espen Technologies, GE, Osram Sylvania, Robertson Worldwide, 

Technical Consumer Products, and Universal all qualify for the NEMA Premium label. 

The NEMA Premium label for fluorescent lamp ballasts is similar to NEMA’s existing 

program for motors. In November 2004, NEMA released state-level shipment data that showed 

an increase in NEMA Premium motor shipments of 30 percent between 2001 and 2002 and 14 

percent between 2002 and 2003.13 

3.2.4.4 ENERGY STAR 

ENERGY STAR is a joint program of DOE and the Environmental Protection Agency 

(EPA) designed to protect the environment by promoting energy efficient products and 

practices.14 ENERGY STAR specifies criteria for residential lighting fixtures, which contain 

three parts: a lamp, a ballast, and the fixture that holds the lamp and ballast. Products that qualify 

for the ENERGY STAR label may not use magnetic ballasts in indoor fixtures. The ENERGY 

STAR specifications also define criteria for lamp start time, power factor, lamp current crest 

factor, ballast operating temperature, electromagnetic interference, frequency, transient 

protection, end of life protection, dimming, and safety.15 

3.2.4.5 Energy Efficient Commercial Building Deduction 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

EPACT 2005 created the Energy Efficient Commercial Buildings Deduction (26 U.S.C 

179D), which establishes a tax deduction for building owners who incur expenses for energy 

efficiency upgrades. Effective for property in service from January 1, 2006 through December 

31, 2008, the deduction allows partial deductions for improvements in interior lighting. Though 

the statute does not specify required lamp types or efficacies, it does call for an overall reduction 

in lighting power density, encouraging the use of higher-performance and reduced-wattage 

fluorescent lamps. The Emergency Economic Stabilization Act of 2008 (HR-1424), approved 

and signed on October 3, 2008, extends the benefits of EPACT 2005 through December 31, 

2013. 

3.2.4.6 Northeast Energy Efficiency Partnerships 

NEEP is a regional nonprofit organization that promotes energy efficiency in the 

Northeast. NEEP runs a High Efficiency Commercial Lighting Initiative to “achieve costeffective energy and demand by overcoming market barriers to the availability and widespread 

market adoption of advanced T8 fluorescent lighting systems.”16 NEEP coordinates with 

multiple local and state governments, utilities, and other initiatives, such as Efficiency Vermontl 

and the Long Island Power Authority, to promote efficient lighting products.17, 18 

3.2.5 Historical Shipments 

Awareness of annual product shipment trends is an important aspect of the market 

assessment and the development of the standards rulemaking. For this rulemaking, DOE used 

publicly available ballast shipments from the U.S. Census from 1990 to 2005.19 DOE also 

obtained confidential shipments from NEMA for 2007. 

DOE used this data for three main purposes. First, the shipment data and market trend 

information contributed to the shipments analysis and base-case forecast for ballasts (chapter 9 

of the preliminary TSD). By using historical shipment data and expert opinion on market trends 

and calibrating forecast assumptions with recent data, DOE believes it has based the shipments 

model and base-case forecasts on a sound dataset. Second, DOE used the data to select the 

representative product classes and representative units for analysis. Generally, DOE selected 

product classes and units to reflect the highest volume, most common ballast types used in the 

United States today (chapter 5 of the preliminary TSD). Third, DOE used the data to develop the 

installed stock of ballasts for the national impact analysis (chapter 10 of the preliminary TSD). 

Based on its understanding of trends in the market, DOE estimated how the market would 

respond to various candidate standard levels. 

The historical shipment data for ballasts is broken down into many subcategories 

beginning with magnetic versus electronic type ballasts. Under each technology type, the 

shipments are categorized by a variety of characteristics. Commercial and residential ballasts are 

delineated by corrected versus uncorrected power factor (section 3.3.3.4). Ballasts are also 

l

 Efficiency Vermont offers technical assistance and financial incentives to encourage energy efficiency in Vermont. 

This organization offers rebates ranging from $10 to $50 for the upgrade to or installation of High Performance T8 

systems. 

3-10 

EERE-2007-BT-STD-0016 COMMENT 25
defined by starting method (section 3.3.3.1), maximum number of lamps driven (one, two, three, 

or four), lamp wattage, lamp diameter, and a few additional specific characteristics. Based on 

interviews with ballast manufacturers, DOE learned that the U.S. Census data represents about 

90 percent of T8 and T5 shipments and about 70 percent of T12 electronic shipments. DOE also 

learned that the U.S. Census does not include shipment data for major residential ballasts or 

dimming ballasts. The Census data also does not provide shipments for every permutation of 

ballast performance characteristics, but does provide data for establishing trends for the major 

categories. Ballasts that operate T8 lamps comprised the majority of shipments in 2005. These 

are followed (in order of 2005 unit sales) by T12 ballasts, compact fluorescent lamp ballasts, T5 

ballasts, and other small subsets. 

Figure 3.2.1 depicts the ballast market based on shipments reported to the U.S. Census in 

2005. 

Figure 3.2.1 2005 Ballast Market Share 

In 2005, corrected power-factor (commercial) magnetic ballasts were not broken out into 

smaller categories for shipments reporting. DOE used subcategory unit shipment proportions 

from the 2000 corrected power-factor magnetic ballast category to extrapolate the disaggregation 

of shipments for 2005. This estimation provided data points for 4- and 8-foot magnetic T12 

ballasts as well as 8-foot HO magnetic T12 ballasts. The 2005 U.S. Census Data also did not 

report magnetic residential and linear dimming ballast shipments. To estimate magnetic 

residential ballast shipments, DOE extended the linear decline in magnetic residential ballasts 

from 2002-2004 to extrapolate a value for 2005. DOE used a similar approach to estimate linear 

dimming ballast shipments. 

Electronic ballasts have slowly replaced magnetic ballasts, as seen in Figure 3.2.2. In 1990, 

magnetic ballasts represented about 96 percent of shipments, while the 2005 magnetic ballast 

market share dropped to 27 percent. This trend was in part due to energy conservation standards 

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EERE-2007-BT-STD-0016 COMMENT 25
 

for T12 ballasts. The most recent energy conservation standards for fluorescent lamp ballasts 

effectively eliminated the sale of 4-foot T12 medium bipin (MBP), 2-foot T12 U-shaped, and 8­

foot T12 slimline magnetic ballasts. The standard began to go into effect for certain 4-foot T12 

MBP, 8-foot T12 slimline ballasts, and 8-foot HO ballasts in 2005. The final phase of the 

standard will be effective in 2010, when replacement 4-foot T12 MBP, 8-foot T12 single pin 

(SP) slimline, and 8-foot HO magnetic ballasts will no longer be sold. (10 CFR 430.32(m)(4)(ii) 

and 430.32(m)(5)-(6)) 

0% 

10% 

20% 

30% 

40% 

50% 

60% 

70% 

80% 

90% 

100% 

Market Share 

Magnetic 

Electronic 

1989 1991 1993 1995 1997 1999 2001 2003 2005 

Year 

Figure 3.2.2 Magnetic and Electronic Ballast Market Share 

The vast majority of 4-foot T12 MBP and 2-foot T12 U-shaped ballasts are magnetic 

(about 77 percent of the T12 market in 2005), and the vast majority of 4-foot T8 MBP and 2-foot 

T8 U-shaped ballasts are electronic (about 97 percent of T8 ballast shipments in 2005). 

Therefore, the decline in magnetic ballasts mirrors a decline in T12 ballast shipments. Similarly, 

the increase in electronic ballasts mirrors an increase in 4-foot T8 MBP and 2-foot T8 U-shaped 

ballast shipments. Figure 3.2.3 and Table 3.2.8 show these shipment trends. The trend in ballast 

shipments is followed by similar trends in 4-foot T8 MBP and 2-foot T8 U-shaped lamp 

shipments and 4-foot T12 MBP and 2-foot T12 U-shaped lamp shipments. DOE received general 

service fluorescent lamp historical shipments from NEMA from 2001 to 2005.20 Based on 

conversations with manufacturers, DOE believes these trends continue beyond 2005. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

0 

5,000 

10,000 

15,000 

20,000 

25,000 

30,000 

35,000 

40,000 

45,000 

50,000 

1994 1996 1998 2000 2002 2004 2006 

Shipments 

Year 

T8s 

T12s 

Figure 3.2.3 Shipments of Ballasts that Operate Four-Foot MBP Lamps 

Table 3.2.8 Shipments of Four-Foot T8 MBP and Two-Foot T8 U-Shaped Ballasts and 

Lamps and Four-Foot T12 MBP and Two-Foot U-Shaped Ballasts and Lamps 

Unit Sales by Year 

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 

Four-Foot 

T12 

Ballast 

(D) (D) 27,227 27,704 26,395 24,463 (D) (D) (D) (D) 11,218 

Four-Foot 

T8 Ballast 23,965 22,317 28,032 30,883 32,488 40,179 44,700 44,215 43,219 45,727 45,951 

Four-Foot 

T8 Lamp (D) (D) (D) (D) (D) (D) 172,143 170,416 179,312 204,922 224,189 

Four-Foot 

T12 Lamp (D) (D) (D) (D) (D) (D) 222,236 215,312 191,391 182,864 171,503 

(D) indicates data not made public. 

Table 3.2.9 shows similar trends for 8-foot T12 and T8 SP slimline ballasts and lamps. In 

general, 8-foot SP slimline T12 ballasts and lamps are experiencing a decrease in shipments, 

whereas 8-foot SP slimline T8 ballasts and lamps are experiencing an increase in shipments. The 

increase in shipments for 8-foot SP slimline T8 lamps is smaller than for 4-foot T8 shipments. 

According to manufacturers and lighting experts, this is because a portion of the 8-foot T12 SP 

slimline ballast market is being transferred to the 4-foot T8 ballast market. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

Figure 3.2.4 Shipments of Eight-Foot Slimline T8 and Eight-Foot SP Slimline T12 Ballasts 

Table 3.2.9 Shipments of Eight-Foot Slimline T8 and Eight-Foot SP Slimline T12 Ballasts 

and Lamps 

Unit Sales by Year 

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 

Eight-Foot 

Slimline T12 

Ballast 

7,394 6,612 6,268 6,601 6,638 5,813 (D) (D) (D) (D) 2,599 

Eight -Foot 

Slimline T8 

Ballast 

932 847 961 959 1,020 1,160 1,547 1,560 1,218 1,214 1,224 

Eight -Foot 

Slimline T12 

Lamp 

(D) (D) (D) (D) (D) (D) 43,265 41,443 37,170 36,263 33,636 

Eight -Foot 

Slimline T8 

Lamp 

(D) (D) (D) (D) (D) (D) 4,405 5,300 5,183 5,727 5,176 

(D) indicates data not made public. 

Table 3.2.10 shows that T12 high-output ballast shipments decreased from 1995 to 2005. 

Data for high output ballasts were not reported in 1997 or from 2001 to 2005. DOE estimated the 

2005 market share using the method described earlier. A portion of the ballasts listed in Table 

3.2.10 are rated for cold-temperature outdoor signage applications, which were excluded from 

previous energy conservation standards. The Census data for high output ballasts are not 

exclusive to ballasts that operate 8-foot RDC HO lamps, but information from manufacturers 

indicates these ballasts represent most of the high output market. Discussions with lighting 

experts and lamp manufacturers indicate that they expect any migration of the 8-foot RDC HO 

market to go toward T5 HO fluorescent systems and metal halide systems. High output ballast 

shipments likely follow a similar trend to the 8-foot HO lamp shipments. Both ballast and lamp 

3-14 

EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

 

Unit Sales by Year* 

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 

Eight-Foot 

T12 RDC 

HO Ballast 

3,538 3,322 (D) 2,305 3,089 2,682 (D) (D) (D) (D) 1,199 

Eight-Foot 

T12 RDC 

HO Lamp 

23,887 24,398 24,206 24,591 25,442 

Eight-Foot 

T8 RDC 

HO Lamp 

691 647 467 674 420 

(D) indicates data not made public. 

shipments show the high output market share is much smaller than for 8-foot slimline T8 and 

T12 ballasts and lamps. 

Table 3.2.10 T12 High-Output Ballast Market Share 

*

Data from 1995 and 1996 include electronic and magnetic ballast shipments. Data from 1997-2005 include only 

magnetic shipments. Lamps shipments are available for 2001-2005 only. 

Based on public data, Figure 3.2.5 shows magnetic residential ballast shipments have 

decreased from 1995 to 2004.m Shipments data for this category were unavailable for 2005. 

Because the major manufacturers in the residential sector are not members of NEMA, shipments 

in the residential sector are likely larger than those reported in the U.S. Census data. Residential 

ballasts have been excluded from energy conservation standards to date. 

14,000 

12,000 

10,000 

8,000

Shipments 

6,000
 

4,000
 

2,000
 

0 

1988 1990 1992 1994 1996 1998 2000 2002 2004 2006 

Year 

Figure 3.2.5 Shipments of Residential Ballasts 

m U.S. Census data does not report shipments of electronic residential (low-power-factor) ballasts. 

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EERE-2007-BT-STD-0016 COMMENT 25
T5 ballasts have been growing steadily since reported shipments began in 2002 (Figure 

3.2.6). T5 normal output ballast shipments were not reported in the U.S. Census data. 

Conversations with ballast manufacturers indicated some growth in normal output T5 ballasts 

due to replacements of 4-foot electronic T8 ballasts. In addition, manufacturers indicated that 

significant growth in T5 ballast shipments has been driven by 4-lamp T5 high output ballast 

systems replacing high-bay metal halide systems in the industrial sector. Based on information 

from ballast manufacturers, DOE believes these trends continued beyond 2005. 

Figure 3.2.6 Shipments of T5 High-Output Ballasts 

3.3 TECHNOLOGY ASSESSMENT 

The purpose of the technology assessment is to develop a preliminary list of technologies 

that could be used to improve the efficiency of fluorescent lamp ballasts. The following 

assessment provides a description of the basic construction and operation of the fluorescent lamp 

and fluorescent lamp ballast, followed by technology options to improve efficiency. 

3.3.1 Basic Structure of Fluorescent Lamps 

The fluorescent lamp is a low-pressure gas discharge source. The lamps are tubular in 

shape and available in a variety of lengths, diameters, and wattages. 

Lamp types are designated by a series of letters and numbers. The letter “F” is used to 

designate a fluorescent lamp. It is followed by a two-digit number that identifies either the 

nominal lamp wattage for nominally 4-foot lamps or the lamp length in inches for 8-foot lamps. 

These digits are followed by the letter “T,” for tubular, which is followed by the lamp diameter 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

 

in eighths of an inch. Additional designations are sometimes used: for example, “HO” if the 

lamp is high output or “/ES” if the lamp is an energy saver or reduced-wattage lamp. Table 3.3.1 

shows the nomenclature that defines the diameter, lamp length, and lamp wattage for some 

common fluorescent lamps. 

Table 3.3.1 Common Linear Fluorescent Lamp Nomenclature 

Lamp Nomenclature Nominal Lamp Length 

feet 

Nominal Lamp Wattage 

W 

Lamp Diameter 

inches 

F32T8 4 32 1 

F40T12 4 40 1 1⁄2 

F54T5 HO 4 54 5/8 

F96T12 8 75 1 1⁄2 

F96T12 HO 8 110 1 1⁄2 

F96T12 HO/ES 8 95 1 1⁄2 

The fluorescent lamp consists of a glass bulb or tube, filled with low pressure mercury 

vapor and inert gas, with electrodes sealed onto both ends of the tube. The fluorescent lamp has 

five major components: bulb, electrodes, base, gas fill, and phosphors. Two electrodes are 

hermetically sealed to both ends of the bulb. The electrodes are usually constructed from coiled 

tungsten wires coated with a mixture of alkaline oxides. A base provides an electrical connection 

to these electrodes and also supports the lamp. Depending on the start method and operational 

properties of the lamp (e.g., dimming, wattage, etc.), lamp designs may use different bases such 

as SP, MBP, and RDC. Once voltage is applied to the electrodes, the tungsten coil and coatings 

emit large quantities of electrons when the coating is at the proper temperature (1,000–1,300 K). 

These electrons then collide with gaseous mercury atoms, exciting electrons within those atoms. 

As the electrons decay to their stable or ground state, they emit UV radiation primarily at 254 

nanometers (nm). In addition to the mercury vapor, an inert gas or a combination of gases is 

added to the lamp primarily to moderate the collisions of mercury ions and minimize evaporation 

of the electrode coating. The UV radiation is then absorbed by the phosphors and reemitted as 

light. 

3.3.2 Electrical Characteristics of a Fluorescent Discharge Lamp 

Regardless of shape, size, or type, all fluorescent lamps require a ballast to initiate and 

maintain the arc discharge. 

To achieve arc formation, the gas plasma has to be excited, ionized, and broken down (to 

become a virtual negative resistance, almost a short circuit). This requires an initial high cathode 

emission and a high electric field (i.e., voltage). Once the arc is achieved, current limiting has to 

be involved to prevent run-away and almost immediate lamp burnout. These two phenomena, 

i.e., ignition and current limiting/control, are required in all fluorescent lamps, regardless of 

shape, size, or type. Both functions constitute the major function of a ballast. Figure 3.3.1 shows 

a graphical representation of this relationship from ignition (Townsend, glow, and abnormal 

glow) through arc discharge. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

Current (I)

Voltage (V)

Arc

Abnormal Glow

Glow

Townsend

Target

Region

Undesirable

Region

Current (I)

Voltage (V)

Arc

Abnormal Glow

Glow

Townsend

Target

Region

Undesirable

Region

Figure 3.3.1 Electrical Characteristic of a Gas Discharge Lamp 

Source: Adapted from Murdoch, Illuminating Engineering: From Edison’s Lamp to the LED, 2nd Edition, 2003. 

A voltage pulse several times that of the lamp operating voltage may be required to 

initiate the arc discharge. During this process, the lamp’s operating point must pass through the 

Townsend, glow, and abnormal-glow as quickly as possible. Rapid start (RS) and programmed 

start (PS) systems use tertiary cathode heating to catalyze this process, while instant start (IS) 

operation simply uses a higher starting voltage. 

In general, tertiary cathode heating is believed to have a positive impact on lamp life. The 

reduction in filament heating caused by instant start operation increases the rate of loss of the 

low–work function coating due to reduced ion bombardment at the cathode (also known as 

sputtering). This causes the tungsten wire coating to deteriorate more rapidly over time, which 

contributes to higher failure rates. Therefore, lamps that operate on RS or PS ballasts can have 

longer lifetimes than lamps that operate on IS ballasts. Lamp life not only depends on the starting 

method of the ballast, but can also depend on the lamp current crest factor. For more information 

on starting method and lamp current crest factor, see section 3.3.3. 

3.3.3 Fluorescent Lamp Ballast Overview 

Fluorescent lamp ballasts are devices that by means of resistance, inductance, 

capacitance, or electronic elements, singly or in combination, control the current, voltage, and 

waveform to properly start and safely operate fluorescent lamps (ANSI C82.13-2002). The 

following sections discuss basic ballast operation and the two main ballast technologies: 

magnetic and electronic. 

A ballast has four critical functions: 

1.	 provide controlled cathode heating to aid in starting and maintaining the arc 

discharge, 

2.	 deliver high voltage to start and ignite the lamp, 

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3.	 regulate (limit) electric current flowing through the lamp after ignition to avoid 

current run-away and self-destruction, and 

4.	 regulate (compensate) for variations in line voltage. Good regulation ensures that 

small variations in line voltage result in even smaller variations in lamp lumen output. 

Ballast types can be subdivided into two main groups: magnetic (low frequency) and 

electronic (high frequency). Magnetic ballasts were the first technology used to operate ballasts. 

Electronic ballasts were developed later in the 1980s because of their high efficiency. Section 

3.3.4 provides additional discussion on these and other technology options that can be used to 

increase the efficiency of fluorescent lamp ballasts. 

There are many performance parameters used to describe the operation of a fluorescent 

lamp ballast. These include starting method, ballast factor, ballast efficacy factor, power factor, 

total harmonic distortion (THD), electromagnetic interference (EMI), and fluorescent system 

safety requirements. These performance parameters are briefly discussed below. 

3.3.3.1 Starting Method 

Fluorescent ballasts can be categorized by the manner in which they operate the lamp, or 

more specifically, how the lamp is started. The most common ballasts use three different 

methods to start a fluorescent lamp: rapid start, programmed start, and instant start. These 

methods are all defined in ANSI C82.11-2002. The starting method primarily affects the ballast’s 

switching cycle capability (i.e., the number of times one can switch the lamp on and off before it 

expires) and the power consumption of the ballast. 

Rapid start ballasts heat the electrodes for a set amount of time before lamp ignition. The 

coil heating reduces the open circuit voltage required to start the lamp, but coil heat remains 

constant after starting and consumes additional power.21 The major benefit of this starting 

technique is that it leads to a longer lamp life than the starting technique of an IS ballast. For 

example, if the lamp is switched on and off every 3 hours, the fluorescent lamp life would be 

approximately 25 percent lower for an IS ballast than for a RS ballast. However, when the lamp 

is frequently switched on and off (e.g., every 15 or 30 minutes), the lamp life on instant start and 

rapid start ballasts can be similar.23 In general, RS ballasts provide between 15,000 and 17,000 

switching cycles.22, 23 

A more recent and advanced version of the RS ballast is the PS ballast. Like the RS 

ballast, the PS ballast heats the lamp filaments to a certain temperature for a prescribed amount 

of time before applying a high-voltage pulse to ignite the lamp. Some programmed start ballasts 

remove all power to the electrodes after ignition (also known as cathode cut-out), resulting in 

some energy savings over other PS systems. However, due to added internal circuitry, PS 

ballasts cannot be as efficient as IS ballasts. PS ballasts can provide between 50,000 to 100,000 

switching cycles depending on ballast design.22, 24 A lamp operating on a PS ballast can last more 

than three times longer than it would on a RS or IS ballast.22 

Instant start ballasts rely on higher voltage to initiate the discharge rather than applying a 

steady filament voltage. These ballasts apply a very high voltage pulse to the lamp to rapidly 

ionize the gas in the lamp and initiate the arc instantly, without the need for heating the 

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electrodes. Because IS electronic ballasts do not provide lamp electrode heating, these ballasts 

are inherently more efficient, saving approximately 2 watts of energy per lamp compared to RS 

ballasts. However, due to the high applied voltage necessary to start the lamp, the electrodes of a 

lamp operated by an IS ballast deteriorate more quickly than the heated electrodes of a lamp 

operated by a RS or PS ballast, resulting in decreased lamp life. IS ballasts can provide between 

10,000 and 15,000 switching cycles depending on the ballast design.22, 23 

3.3.3.2 Ballast Factor 

The ballast factor is defined as the output of a ballast delivered to a reference lamp in 

terms of power or light divided by the output of the relevant reference ballast delivered to the 

same lamp (ANSI C82.13-2002). To calculate the light output of a lamp-and-ballast system, one 

would multiply the light output of the lamp by both the number of lamps operated by the ballast 

and its ballast factor. Because ballast factor affects the light output of the system, manufacturers 

design ballasts with a range of ballast factors to allow consumers to vary the light output (and 

thus power consumed) of a fluorescent system. In general, ballasts designed with a ballast factor 

of around 0.88 are deemed normal ballast factor. Low ballast factor ballasts have a ballast factor 

of 0.78 or less; high ballast factor ballasts typically have a ballast factor of 1.10 or higher. 

3.3.3.3 Ballast Efficacy Factor 

Ballast efficacy factor (BEF) is a measure of ballast system performance or efficacy. 

According to Appendix Q to Subpart B of Part 430 in the CFR, this factor is defined as: 

Relative Light Output BEF = Equation 3.1 Input Power 

Where: 

BEF = ballast efficacy factor; 

Relative Light Output = the light output delivered through the use of a ballast divided by the 

light output delivered through the use of a reference ballast, expressed as a percent; and 

InputPower = the power consumption in watts of a ballast and fluorescent lamp or lamps. 

3.3.3.4 Power Factor 

The power factor (PF) is calculated by determining the ratio of the active power to the 

apparent power. PF depends on the current’s wave shape as well as the phase relationship 

between the current and the voltage. The power input is measured with a wattmeter capable of 

indicating the average power in watts. The ballast input voltage multiplied by the ballast input 

current is the ballast’s apparent power (ANSI C82.13-2002). 

Power Input Power Factor = Equation 3.2 Ballast Input Voltage ∗ Ballast Input Current 

Where:
 

PowerFactor = power factor, 

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PowerInput = input power in watts to ballast, 

BallastInputVoltage = input voltage in volts to ballast, and 

BallastInputCurrent = input current in amps to ballast. 

Power factors range between 0 and 1. A power factor of 1 indicates that the voltage and 

current wave forms are in phase and not distorted. Fluorescent ballasts can be characterized by 

two classes of power factor: high power factor (HPF) of 0.9 or greater, and normal power factor 

(NPF) of 0.6 or greater. HPF ballasts use about one-half the current of NPF ballasts. The primary 

cause of low power factor in magnetic ballasts is the inductance of the ballast transformers. It 

can be corrected with the addition of the proper capacitor. In electronic ballasts, the primary 

cause of low power factor is due to total harmonic distortion (defined below) caused by a nonlinear load. According to ANSI C82.77-2002, commercial ballasts must have a HPF while 

residential fluorescent ballasts (with an input power below 120W) must have a power factor of 

0.5 or greater. 

3.3.3.5 Total Harmonic Distortion 

Another important performance parameter is harmonic distortion. Line current harmonics 

are the components of the line current that oscillate at integer multiples of the fundamental 

frequency of the power supply, e.g., 60 Hz, 120 Hz, 180 Hz, etc. Harmonics of a fundamental 

frequency are an undesirable byproduct of any non-linear system operation, generating noise and 

wasted power. Total harmonic distortion refers to the ratio of the root mean square (rms) values 

of the harmonic content to that of the fundamental current, expressed as a percentage. It may also 

be called harmonic factor: 

2 2 2 I + I + I + ... 2 3 4 THD( fund) =

I1

2 

Equation 3.3 

Where: 

THD = total harmonic distortion; and 

I n =the rms current of harmonic n, where n=1 is the fundamental harmonic. 

High THD figures are not acceptable and are detrimental to many kinds of electronic devices 

connected to the power line. They are also considered a “pollutant” to the environment because
 

of radio frequency noise. Therefore, ANSI C82.11-2002 requires that the THD of electronic 

ballasts not exceed 32 percent. Electronic ballasts today are typically rated at less than 20 percent
 

THD. Magnetic ballasts are typically rated in the 20 to 28 percent range.
 

3.3.3.6 Electromagnetic Interference 

Many devices found in office environments, such as computers, photocopiers, facsimile 

machines, and fluorescent lighting systems, can generate electromagnetic waves. The effects of 

these waves vary based on their strength and the susceptibility of nearby equipment. Alternating 

current in electronic devices produces a magnetic field, which in turn induces an AC voltage in a 

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nearby electronic device. Electromagnetic interference (EMI) takes two forms: conducted or 

radiated. Conducted EMI occurs when electronic devices induce currents in the local power 

network that in turn negatively affect other devices on that network. Radiated EMI is associated 

with the electric and magnetic field inherent in electronic devices. EMI can be minimized with 

proper grounding and wiring techniques.25 EMI limits for both consumer and non-consumer 

lighting products sold in the United States are listed in 47 CFR 18 subpart C. These regulations 

require that consumer/residential (Class B) ballasts have lower maximum EMI requirements than 

non-consumer (Class A) products. The International Committee on Radio Interference has more 

stringent regulations concerning EMI. However, fluorescent lamp ballasts sold in the United 

States currently do not have to meet these regulations. 

3.3.3.7 Safety 

A ballast will continue to drive or reignite a lamp when the lamp reaches the end of its 

life. Usually, the failure of the lamp will have no adverse consequences. Occasionally, the ballast 

will continue to try to drive a failed lamp repeatedly until the temperature in the region of the 

electrode increases rapidly and causes overheating of the lamp electrodes. This can be avoided 

through additional circuitry that provides end-of-life (EOL) protection. Some ballasts in the 

United States are required to have EOL protection (e.g., ballasts that operate T5 lamps). 

However, the most popular T8 ballasts are not. International standards (IEC 600797-1 Ed. 4) 

require all fluorescent lamp ballasts regardless of lamp diameter to have EOL protection. 

Another safety issue arises when a lamp is not inserted properly into the lamp holder, 

which can cause arcing. This problem can either be addressed through better design of the lamp 

holders, or by adding circuitry to the ballast that detects arcing and reduces the output voltage so 

that the arc cannot be sustained. 

3.3.4 Fluorescent Lamp Ballast Technology Options 

The following section discusses the two major technologies used in fluorescent lamp 

ballast design—magnetic ballasts and electronic ballasts—and additional technology options 

(lamp diameter, improved components, and improved circuit design) that can incrementally 

improve the efficiencies of a magnetic or electronic ballast. 

3.3.4.1 Magnetic Ballasts 

The main components of a magnetic ballast are a magnetic choke to limit the current, a 

step-up transformer to obtain a high starting voltage, and a capacitor that corrects for the ballast’s 

low power factor. Multi-lamp magnetic ballasts also have one or more additional capacitors to 

sequence the starting of the lamps. Magnetic ballasts operate at an input frequency of 60 Hz and 

operate the lamp(s) at the same frequency. 

The main core-and-coil assembly consists of a capacitor and laminated transformer steel 

wound with copper or aluminum magnet wire. The assembly is infused with a potting material 

(e.g., hot asphalt) containing fiber such as silica and housed in a steel case. Figure 3.3.2 presents 

a labeled graphic of the interior of a standard magnetic ballast. 

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Figure 3.3.2 Cutaway View of a Typical Magnetic Fluorescent Ballast 

The core and coil assembly functions as a voltage transformer and a current limiter 

(choke). A capacitor enables the ballast to use energy from the alternating current power line 

more efficiently, which is then referred to as a HPF or PF corrected ballast. The purpose of the 

insulating material is to conduct heat away from the transformer coils and ensure tightness of 

transformer coils to eliminate vibrational noise. 

Because of their low frequency operation, magnetic ballasts are less energy efficient than 

electronic ballasts (Figure 3.3.3). Magnetic ballasts fail to optimize lumen output for a given 

wattage. These ballasts also release the energy not used to operate the lamp as heat in the 

transformer windings. This heat is dissipated to the environment by the ballast potting material 

and its metal or plastic enclosures. 

3.3.4.2 Electronic Ballasts 

For equivalent light output, electronic ballasts consume about 10 to 30 percent less 

energy than magnetic ballasts. An electronic ballast starts and operates fluorescent lamps at 

frequencies greater than 20 kHz using electronic components rather than the traditional core and 

coil assembly. The electronic ballast takes the input 60 Hz power, rectifies it, and converts it into 

a high frequency using an oscillator circuit. 

Higher operating frequency generates greater lumen output. Figure 3.3.3 shows the 

increase in lumen output relative to 60 Hz operation as a function of frequency. The gain in light 

output by increasing operating frequency begins to plateau around 20 kHz. Therefore, electronic 

ballasts typically operate at frequencies above 20 kHz. 

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Figure 3.3.3 Fluorescent Lamp Efficacy vs. Operating Frequency of Lamp 

Source: Adapted from IESNA, 2002. 

Not only is the lamp more efficient at higher frequencies but the ballasting action 

(current-limiting) at high frequency requires smaller components. This reduces ballast losses and 

makes the ballast more efficient. In addition, the ballast noise becomes inaudible at higher 

frequencies and there is no 60-cycle flicker like that associated with fluorescent lamps that 

operate with magnetic ballasts. 

Whereas typical magnetic ballasts generally have three components (i.e., core, coil, and 

capacitor), electronic ballasts have additional blocks of electronic components. Figure 3.3.4 

shows the interior of an electronic ballast. 

Figure 3.3.4 Cutaway View of an Electronic Fluorescent Ballast 

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Figure 3.3.5 presents an example of a functional block diagram of a fixed-light output 

electronic ballast. Auxiliary functions performed by a typical electronic ballast include 

electromagnetic interference filtering to block ballast-generated noise, input rectification, PF 

correction for sinusoidal input current, a direct-current (DC) filter, a direct-current to alternatingcurrent (DC-AC) inverter, a feedback/controller for high-frequency operation, and a final output 

stage to power the lamp. 

Figure 3.3.5 Fixed-Light Output Electronic Fluorescent Ballast Block Diagram 

Source: T. Ribarich, A Systems Approach to Ballast IC Design, El Segundo, CA, 1999, and Philips Semiconductor, 

Power Semiconductor Applications, 1994. 

Table 3.3.2 provides a description of each component in a typical electronic ballast, the 

efficiency impact of these components, and the waveform at each stage of the fluorescent lamp 

ballast circuit. 

Table 3.3.2 Basic Building Blocks of a Fixed-Light Output Fluorescent Lamp Ballast and 

Associated Characteristics 

Circuit Stage Function Efficiency 

Impact 

Waveform (not to 

scale) 

EMI Filter 

Impedes EMI by providing a high impedance 

path to EMI and a low impedance path to the 

desired input. The circuit also protects against 

high voltage pikes. 

Very Low 

t 

V 

Begins to convert incoming AC to DC using 

diodes. A full-bridge rectifier, one type of 

input rectifier, is composed of four diodes, 

which “rectify” the full AC waveform as 

shown in the waveform on the right. The 

current is not in phase with the voltage. 

Low 

t 

V, I 

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Input Rectifier 

Power Factor 

Correction 

Corrects the current so it is in phase with the 

voltage. Power factor correction can be 

achieved through a buck or boost-converter 

circuit topology. 

Low-Medium 

t 

V, I 

DC Filter 

Reduces “ripple” of the DC current waveform 

using capacitors. The most common type of 

capacitor used is the electrolytic capacitor. 

Low 

t 

V 

DC-AC Inverter 

Converts incoming DC to high-frequency AC. 

The resonant half-bridge self-oscillating 

circuit is one type of circuit topology that can 

be used to accomplish this task. 

MediumHigh 

t 

V 

Output Stage 

When the lamp is not started, the circuit 

operates in resonance to increase output 

voltage to start the lamp. Once the lamp is 

started, the circuit operates at a frequency off 

of resonance to continue operating the lamp. 

A resonant filter topology is one type of 

circuit topology used in the output stage. 

High 

Starting: 

t 

V 

Operation: 

t 

V 

Feedback/Controller An integrated circuit (IC) that controls the 

frequency output of the DC-AC inverter. It 

can also protect against under voltage lockout 

Low N/A 

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and lamp faults. 

3.3.4.3 Lamp Diameter 

Lamp diameter is another design parameter of a fluorescent lamp ballast that can affect 

the ballast efficacy factor. As discussed in section 3.4, product classes are not explicitly 

segregated by the lamp diameter operated by the ballast. When DOE determines that changes in 

lamp diameter offer a distinct utility, DOE may establish separate product classes. In general, 

however, DOE considers lamp diameter to be a technology option. 

The diameter of a lamp affects both the lamp efficacy and the ballast’s BEF. For lamps, 

an optimum design diameter exists for a specific fluorescent lamp type resulting from two 

opposing effects. First, in small diameter lamps, an increase in diameter decreases the number of 

electrons and mercury ions that recombine at the bulb wall and produce no light. This lessening 

of non-radiative recombination results in an increase of optical power output and subsequently a 

rise in lamp efficacy. However, when the lamp diameter is sufficiently large as to result in 

minimal non-radiative recombination, a second opposing effect begins to influence the efficacydiameter relation. With these larger diameter lamps, a further enlargement in diameter causes a 

greater imprisonment of radiation within the lamp. As the total light output is reduced, the lamp 

efficacy declines as well. In general, T12 lamps are less efficient than T8 lamps. 

For ballasts, lamp diameter affects the BEF of a ballast in the following manner. Because 

T12 lamps are less efficient than T8 lamps, lamp manufacturers can achieve similar light output 

using lower-wattage T8 lamps. Ballasts that operate lower-wattage T8 lamps use less power to 

operate the lamp at a similar ballast factor than higher-wattage T12 lamps. Therefore, the BEF of 

the ballast operating a T8 lamp is generally higher than that of a ballast operating a T12 lamp. 

Because the BEF and lamp efficacy of a T8 fluorescent system are higher than that of a T12 

fluorescent system, T8 systems are more efficacious than T12 systems. 

DOE only considered lamp diameter as a technology option for T12 and T8 lamps. 

DOE’s research indicates that ballasts that operate T8 lamps are common replacements for 

ballasts that operate T12 lamps. Although the lumen packages for ballasts that operate T8 lamps 

are sometimes lower than that of ballasts that operate T12 lamps, in this situation, it does not 

seem to be significant enough to affect consumer utility. Conversely, DOE’s research indicates 

that ballasts that operate T5 lamps are not commonly used as substitutes for their T8 or T12 

counterparts. T5 lamps require different lamp holders due to differences in lamp length and base 

type. In addition, because T5 lamps have similar total lumen output as T8 and T12 lamps over a 

significantly smaller surface area, T5 lamp-and-ballast systems are often marketed as too bright 

for use in direct lighting fixtures. As such, ballasts that operate T5 lamps are not considered a 

technology option for improving the ballast efficacy factor of T8 and T12 ballasts. 

3.3.4.4 Improved Components 

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A common way to increase the efficiency of both magnetic and electronic ballasts is to 

improve the quality of their components. Transformers, diodes, capacitors, and transistors are the 

main components that affect efficiency. 

Transformers: In electronic ballasts, transformers influence the efficiency of the EMI, 

power factor correction (PFC), and output stage of the ballast. In magnetic ballasts, transformers 

influence the efficiency of the output stage and current-limiting portion of the ballast. 

There are two loss mechanisms associated with transformers: core losses and winding 

losses. Core losses involve the magnetic properties of the core material, which exhibits power 

losses in the form of hysteresis and eddy currents within the core itself. Winding losses come 

from the resistance in the winding, typically copper. There are several technology options that 

can improve the efficiency of a transformer’s core losses. These include improved silicon steel, 

amorphous steel, or increased amounts of amorphous steel. Litz wire can be used as a technology 

option to improve a transformer’s winding losses. 

One way to reduce transformer power loss at light loads is to select a transformer with 

higher quality core materials. There are two types of core materials that ballasts can use: silicon 

steel (thinly laminated steel alloyed with silicon) and amorphous steel. Core performance of 

silicon steel can be enhanced by magnetically orienting the grain structure in the metal. Even 

larger gains in efficiency can be achieved using amorphous materials. To further increase the 

efficiency of the ballast using amorphous materials, one can create the core of the inductor from 

laminated sheets of amorphous steel, insulated from each other. However, this method can 

increase the size and weight of the ballast. 

Another way to reduce the transformer’s power loss is to select materials with lower 

winding losses. High-frequency operation (typical of electronic ballasts) can increase winding 

losses as two additional loss mechanisms, skin effect and proximity effect, become more 

prominent. One way to reduce both the skin effect and proximity effect is to use litz wire, which 

consists of a number of individually insulated magnet wires twisted or braided into a uniform 

pattern. Skin effect refers to the tendency of AC current to flow through a conductor’s surface or 

“skin” rather than a conductor’s core. Because litz wire increases the amount of surface area 

current can flow through, overall winding losses can be reduced as the effective wire resistance 

is decreased. When conductors are close together, the magnetic field of one conductor will 

reduce the area that the current flows through in another conductor, increasing its winding losses. 

This effect, called the proximity effect, can be also be improved by using litz wire. 

Diodes: In electronic ballasts, the input rectifier inverts the negative half of the AC sine 

wave and makes it positive. Several technology options can be used to improve the efficiency of 

this portion of the circuit. The power consumed by a diode is the product of the current flowing 

through the diode multiplied by the voltage drop across it. Conventional diodes have a voltage 

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drop of about 0.6 V. Using Schottky diodesn reduces the voltage drop across the diodes by about 

0.3 V to 0.4 V. 

Capacitors: In both magnetic and electronic ballasts, capacitors are used in the PFC and 

output stage of the circuit design. In electronic ballasts, capacitors are also used in the DC Filter 

stage of the electronic circuit. One way to improve the efficiency of each portion of the circuit is 

to use capacitors with low effective series resistance (ESR). Capacitors with a low ESR are also 

more reliable because they are cooler than capacitors with a higher ESR. 

Transistors: In electronic ballasts, transistors are used in both the power factor correction 

and the DC-AC inverter portion of the circuit. The transistor dissipates energy due to its drain-tosource resistance (RDS_ON) when the current flows through the transistor to the transformer. 

Using transistors with low RDS_ON can reduce this loss. For example, the efficiency of electronic 

ballast’s bipolar transistors can be improved by using metal-oxide-semiconductor field-effect 

transistors (MOSFETs), a transistor with a lower drain-to-source resistance. 

3.3.4.5 Improved Circuit Design 

Another method of increasing the efficiency of both magnetic and electronic ballasts is to 

improve the ballast’s circuit design. Examples of improved circuit design include cathode cutout 

technology, integrated circuits, improved starting method, and synchronous rectification. 

Cathode Cutout: Both rapid start and programmed start ballasts provide heat to the 

filament while starting a lamp. As discussed in section 3.3.3.1, providing filament power while 

starting the lamp can increase its lifetime. Removing the power provided to the filament after the 

lamp has been started using an electronic circuit will increase the efficiency of both programmed 

start and rapid start ballasts. Removing this power can reduce the power the ballast consumes by 

as much as 2 watts per lamp. 

Integrated Circuits: In certain cases, a ballast’s efficiency can be improved by 

substituting integrated circuits for discrete components. For example, some ballasts use bipolar 

transistors in a resonant half-bridge self-oscillating circuit to convert incoming DC to AC. The 

efficiency of this circuit can be improved by substituting the components in that circuit with an 

integrated circuit.26 

Starting Method: RS and PS ballasts are inherently less efficient than IS ballasts, which 

use extra power to provide filament power to the ballast to increase its lifetime. Although these 

ballasts can cut out the filament power during lamp operation (using the cathode cutout 

technology option discussed above), the extra circuit to remove this power uses some amount of 

power. 

DOE only considered starting method as a technology option in case of the migration 

from RS to IS ballasts. DOE’s research indicates that IS ballasts are common replacements for 

n

 A Schottky diode is a metal semiconductor diode with a smaller voltage drop than a conventional diode. Schottky 

diodes therefore consume less power. 

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RS ballasts, and though the lamp lifetime is sometimes lower in IS ballasts than RS ballasts, it 

does not seem to be significant enough to affect consumer utility. As discussed in section 3.3.3.1, 

lamp lifetime in IS ballasts is approximately 25 percent less compared to RS ballasts when 

operated on a 3-hour start. However, lamps operated on RS ballasts have the same lifetime as 

lamps operated on IS ballasts when operated on short start cycles. This is typical when ballasts 

are used with occupancy sensors to save energy. Conversely, the lifetime of a lamp that operates 

on a PS ballast with occupancy sensors can be as much as three times longer than the lifetime of 

a lamp that operates on an IS or RS ballasts. Because IS ballasts have more limited utility as 

replacements for PS ballasts, IS ballasts are not considered a technology option for improving 

the efficiency of PS ballasts. 

3.4 PRODUCT CLASSES 

When evaluating and establishing energy conservation standards, DOE divides covered 

products into classes by the type of energy used, capacity, or other performance-related features 

that affect efficiency, and factors such as the utility of the product to users. (See 42 U.S.C. 

6295(q)) DOE then conducts its analysis and considers establishing or amending standards to 

provide separate standard levels for each product class. DOE applied the criteria of 42 U.S.C. 

6295(q) to fluorescent lamp ballasts to develop product classes for this preliminary TSD. This 

section describes the product classes DOE considers for this rulemaking. 

In amending EPCA, NAECA 1988 established eight product classes for fluorescent lamp 

ballasts (Table 3.4.1). 

Table 3.4.1 EPCA Product Classes Established by NAECA 1988 for Fluorescent Lamp 

Ballasts 

Application for Operation of Ballast Input Voltage Total Nominal Lamp Watts 

One F40T12 Lamp 120 40 

277 40 

Two F40T12 Lamps 120 80 

277 80 

Two F96T12 Lamps 120 150 

277 150 

Two F96T12 HO Lamps 120 220 

277 220 

In further amendments to EPCA, EPACT 2005 established an additional eight product 

classes for fluorescent lamp ballasts (Table 3.4.2). 

Table 3.4.2 EPCA Product Classes Established by EPACT 2005 for Fluorescent Lamp 

Ballasts 

Application for Operation of Ballast Input Voltage Total Nominal Lamp Watts 

One F34T12 Lamp 120 34 

277 34 

Two F34T12 Lamps 120 68 

277 68 

Two F96T12/ES Lamps 120 120 

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277 120 

Two F96T12 HO/ES Lamps 120 190 

277 190 

In addition to the lamps and lamp ballasts identified in Table 3.4.1 and Table 3.4.2, the 

fluorescent lamp ballast market today includes ballasts that operate smaller diameter lamps such 

as T8 and T5 lamps (section 3.3.1). These fluorescent lamp-and-ballast systems are gaining in 

market share, whereas T12 systems are becoming less popular and losing market share. This 

market shift is expected to accelerate in 2010, when the exclusion from the standard levels 

established by the 2000 Ballast Rule and EPACT 2005 for replacement ballasts will expire. The 

standard levels established by the 2000 Ballast Rule and EPACT 2005 for fluorescent lamp 

ballasts are difficult to meet using magnetic ballast technology. Because magnetic ballasts 

comprise the large majority of T12 ballast sales, DOE believes that when the standards take 

effect, there will be an increase in shipments of electronic ballasts that operate T8 and T5 lamps. 

Because of these market changes and because DOE is anticipating expanding its scope of 

covered product for fluorescent lamp ballasts, DOE is considering amending the product classes 

for these ballasts. The following sections summarize all of the factors that DOE considered as 

potential determinants of product class. In general, when considering the characteristics below, 

DOE considered three main factors as affecting consumer utility: (1) the lumen package of the 

lamp-and-ballast system; (2) the physical constraints of the lamp-and-ballast system; and (3) the 

use of the ballast in an application for which other ballasts are either not suitable. When referring 

to efficiency, DOE is referring to BEF. 

3.4.1 Lamp Length 

The fluorescent ballasts considered for coverage are designed to operate lamps with 

lengths of four or eight feet. Because BEF is a function of ballast input power, and input power is 

highly dependent on the length of the lamp operated by the ballast, all else being equal, a ballast 

operating a shorter lamp generally has a higher BEF than the same ballast operating a longer 

lamp. Furthermore, because consumers are often physically constrained by their building ceiling 

layout, systems operating 8-foot and 4-foot lamps are not always substitutable for each other. 

Therefore, DOE believes that lamp length affects consumer utility. Given the impact on BEF and 

utility, DOE is establishing separate product classes for ballasts that operate different lamp 

lengths. 

3.4.2 Lamp Diameter 

T8 lamp-and-ballast systems are generally more efficient than T12 lamp-and-ballast 

systems and T8 ballasts generally have higher BEFs than T12 ballasts. DOE does not, however, 

believe that this alone justifies creating separate product classes for ballasts that operate T8 and 

T12 lamps. Consistent with its approach in past rulemakings (74 FR 16920, 16937 (April 13, 

2009)), DOE maintains that T8 lamp-and-ballast systems are commonly used as substitutes for 

T12 lamp-and-ballast systems, suggesting that there is no unique utility associated with T12 

systems. Manufacturer marketing literature and general guidance on lighting design and 

installation often promote T8 lamp-and-ballast systems as energy saving substitutes for T12 

systems. Such substitute systems often have the same lengths and bases, offer comparable lumen 

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output, and can fit within the same fixtures. DOE recognizes that lamp diameter may affect 

ballast BEF, but the utility provided to the end-user is comparable and/or equivalent. Therefore, 

DOE has decided to include ballasts that operate T8 and T12 lamps in the same product class. 

However, DOE has decided to establish a separate product class for ballasts that operate 

T5 lamps. All else being equal, 4-foot T5 ballasts generally have lower input power (due to the 

lower wattage of the test lamp), and therefore higher BEF than T8 or T12 ballasts. These 

systems, though often used to replace T8 and T12 systems, are not viable substitutes in all 

applications. Because T5 lamps have similar total lumen output as T8 and T12 lamps over a 

significantly smaller surface area, T5 lamp-and-ballast systems are often marketed as too bright 

for use in direct lighting fixtures. To prevent eliminating lamps appropriate for direct lighting 

applications, DOE has tentatively decided to establish separate product classes for ballasts that 

operate T5 lamps. 

3.4.3 Ballast Factor 

The ballasts considered for coverage in this rulemaking are available with a range of 

ballast factors. In applying DOE’s proposed amended active mode test procedure (as presented 

in the active mode test procedure NOPR), DOE found that ballasts with high or low ballast 

factors have lower BEFs than ballasts with a normal ballast factor.o

 Furthermore, ballast factor is 

typically used to adjust the lumen package of a lamp-and-ballast system. Lumen package refers 

to the quantity of light that a lamp-and-ballast system provides to a consumer. DOE has observed 

that consumers tend to use systems with different lumen packages for different applications. For 

example, low BF ballasts (with smaller lumen packages) are commonly used in applications 

where less light is desired. In consideration of the effect that ballast factor has on both BEF and 

consumer utility, DOE has decided to establish separate product classes for low, normal, and 

high ballast factor ballasts. 

3.4.4 Lumen Package 

Lumen package refers to the quantity of light that a lamp-and-ballast system provides to a 

consumer. To obtain a high lumen package, certain lamps are designed to operate with ballasts 

that run the lamps at high currents. For example, 8-foot RDC HO lamps and 4-foot miniature 

bipin (MiniBP) HO lamps tend to operate at higher currents than 8-foot SP slimline lamps and 4­

foot MiniBP standard output (SO) lamps, respectively. This difference in operating design 

increases the quantity of light per unit of lamp length. 

High output lamps generally operate at higher wattages than comparable (same length, 

diameter) standard output lamps. For example, for 4-foot miniature bipin lamps, the most 

common high output lamp has a wattage of 54 W whereas the most common standard output 

lamp has a wattage of 28 W. This difference in lamp wattage means that ballasts that operate 

high output lamps generally have lower BEFs than ballasts that operate comparable standard 

output lamps. 

o

 DOE classifies a low BF as less than or equal to 0.78, a normal BF as greater than 0.78 but less than 1.1, and a high 

BF as greater than or equal to 1.1. 

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In addition, consumers tend to use systems with different lumen packages for different 

applications. For example, high-lumen-output systems may be installed in certain high-ceiling or 

outdoor applications where large quantities of light are needed. Alternatively, standard-lumenoutput systems might be installed in lower-ceiling applications such as offices or hospitals, 

where, for example, distance between the light source and the illuminated surface is not as large. 

Notable differences in the application of ballasts designed to operate SO lamps versus HO lamps 

indicate a difference in utility. 

Therefore, given the observed utility distinctions and notable efficacy differences, DOE 

is establishing separate product classes for ballasts that operate SO lamps and ballasts that 

operate HO lamps. 

3.4.5 Maximum Number of Lamps Operated 

Ballasts are designed to operate a certain maximum number of lamps. For example, 

ballasts designed to operate 4-foot MBP lamps can operate as few as one or as many as six 

lamps. DOE found that BEF decreased with each additional lamp operated by a ballast. This is 

because additional lamps increase the ballast’s input power, which appears in the denominator of 

Equation 3.1. DOE believes that the ability to operate different maximum number of lamps 

offers the consumer a distinct utility because this capacity affects the space required by fixtures 

(a four-lamp fixture requires more physical space than one-lamp fixture). Given this impact on 

both BEF and consumer utility, DOE has decided to establish separate product classes based on 

the maximum number of lamps a ballast operates. 

3.4.6 Starting Method 

As discussed in section 3.3.3.1, the starting method of a ballast affects its efficiency. RS 

and PS ballasts are inherently less efficient than IS ballasts as these ballasts use extra power to 

provide filament power to the lamp to increase the lamp’s lifetime. Although these ballasts can 

cut out the filament power during lamp operation (using the cathode cutout technology option 

discussed above), the extra circuit to remove this power uses some amount of power. 

Whereas RS and IS ballasts are commonly used as substitutes for each other, 

programmed start ballasts are not. PS ballasts are commonly used in conjunction with 

occupancy sensors because of their ability to maintain the lifetime of the fluorescent lamp. 

DOE’s research indicates that use of instant start ballasts with occupancy sensors can result in an 

80 percent reduction in lamp lifetime. Because of the application in which they are used, 

programmed start ballasts offer the user a distinct utility. In consideration of its affect on both 

BEF and utility, DOE has tentatively decided to establish separate product classes for 

programmed start ballasts 

3.4.7 Input Voltage 

Fluorescent lamp ballasts are available at a variety of input voltages, but the two most 

common input voltages are 120V and 277V. In examining test data between ballasts that operate 

only at 120V and ballasts that operate only at 277V, DOE found that there was not a significant 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

difference in BEF. In addition, in its research, DOE found that the ballasts with the highest BEFs 

allowed operation at both 120V and 277V. For this reason, DOE does not consider input voltage 

to be a factor in determining product class. 

3.4.8 Universal Voltage 

Universal voltage ballasts can operate at multiple input voltages (e.g., 120V and 277V). 

To accommodate multiple voltages, these ballasts contain more components than dedicated 

voltage ballasts (ballasts that operate only one input voltage). Universal ballasts are growing in 

popularity because they can be used in multiple applications and serve as replacements for 

multiple ballasts. This allows distributors to stock fewer types of ballasts and allows contractors 

to keep fewer on hand for maintenance. Consolidation of products creates economies of scale for 

manufacturers, which can lead to reduced production costs. DOE compared test data between 

ballasts that operate only at one voltage and universal voltage ballasts operating at that voltage 

and found that there was not a significant difference in BEF between the two. Therefore, DOE 

does not consider operating at multiple voltages to be a factor in determining product class. 

3.4.9 Residential Ballasts 

Separate minimum power factor and electromagnetic interference requirements exist for 

residential as compared to commercial ballasts. Residential ballasts have more stringent (or 

lower maximum allowable) electromagnetic interference requirements than commercial ballasts; 

they also have less stringent (or lower minimum allowable) power factor requirementsp

. These 

differing requirements between commercial and residential products result in differing BEFs. In 

addition to their effect on BEF, these two requirements offer the consumer a unique utility in that 

they serve distinct market sectors and applications. Therefore, DOE has tentatively decided to 

establish a separate product classes for ballasts that operate in the residential sector and 

commercial sector. 

3.4.10 Sign Ballasts 

Ballasts that are designed for use in cold temperature outdoor signs have slightly different 

characteristics than those ballasts that operate in the commercial or residential sectors. First, sign 

ballasts are designed to operate in cold temperature environments – as low as -20 °F. Second, 

sign ballasts are classified by the total length (in feet) of lamps they can operate as well as the 

total number of lamps. To operate in cold temperature environments and to be able to handle 

numerous lamp combinations, sign ballasts contain more robust components compared to 

ballasts in the commercial sector that operate 8-foot HO lamps and therefore sign ballasts are 

inherently less efficient. Regular 8-foot HO ballasts cannot be used as substitutes due to their 

inability to operate in cold temperature environments. For this reason, DOE believes cold 

temperature sign ballasts offer the consumer a distinct utility. Therefore, DOE has established a 

separate product class for cold temperature sign ballasts. 

p

 ANSI C82.77-2002 requires residential ballasts to have a minimum power factor of 0.5 and commercial ballasts to 

have a minimum power factor of 0.9. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

 

 

 

 

 

 

 

 

3.4.11 Product Classes 

For all the reasons discussed above, DOE is considering the ballast product classes listed 

in Table 3.4.3. Although ballasts are designed to operate multiple wattages of lamps, energy 

conservation standards will only be specified for the most common lamp wattage in each product 

class. In addition, energy conservation standards will only be specified while a ballast is 

operating the maximum number of lamps it is designed to operate. Chapter 5 of this preliminary 

TSD provides detail on the selection of candidate standard levels. 

Table 3.4.3 Preliminary Product Classes for Fluorescent Lamp Ballasts 

Ballast and Lamp Number of Lamps 

Type 

Starting 

Method 

Ballast 

Factor One Two Three Four Five Six 

High 1 2 3 4 5 6 

IS and RS Normal 7 8 9 10 11 12

Low 13 14 15 16 17 18 

High 19 20 21 22 23 24 

Normal 25 26 27 28 29 30 

Four-Foot MBP, 

and Two-Foot UShaped 

PS 

Low 31 32 33 34 35 36 

High 37 38 N/A N/A N/A N/A 

Normal 39 40 N/A N/A N/A N/A 

Four-Foot T5 

MiniBP SO All 

Low 41 42 N/A N/A N/A N/A 

Four-Foot T5 

MiniBP HO All All 43 44 45 46 N/A N/A 

High 47 48 N/A N/A N/A N/A 

Normal 49 50 N/A N/A N/A N/A Eight-Foot SP 

Slimline All 

Low 51 52 N/A N/A N/A N/A 

Eight-Foot RDC IS and RS All 53 54 N/A N/A N/A N/A 

HO PS All 55 56 N/A N/A N/A N/A 

IS and RS All 57 58 59 60 N/A N/A Residential Ballast, 

Four-Foot MBP, 

and Two-Foot UShaped PS All 61 62 63 64 N/A N/A 

Sign Ballast All All 65 66 67 68 69 70 

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