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This is a draft document and does not represent a definitive view of the agency on the questions 

addressed.

This and other guidance documents are accessible on the U.S. Department of Energy, Energy Efficiency 

& Renewable Energy web site at: http://www1.eere.energy.gov/guidance/default.aspx?pid=2&spid=1.

Guidance Type: Test Procedures

Category: Commercial and Industrial Equipment

Equipment: Illuminated Exit Signs

Guidance Version: DRAFT

Issued: June 6, 2013

This guidance represents DOE’s interpretation of its existing regulations and is exempt from the notice 

and comment requirements of the Administrative Procedure Act. See 5 U.S.C. § 553(b)(A). Nevertheless, 

given that the Department has not previously expressed its views on this issue, we are interested in 

receiving feedback from the public. Therefore, the Department is accepting comments and suggestions 

from the public until July 8, 2013. Comments and suggestions should be provided in WordPerfect, 

Microsoft Word, PDF, or text file format by sending an email to IExS-Guidance-2013-CE0078@ee.doe.gov. Please also include the docket number: EERE-2013-BT-CE-0078. At the end of the 

comment period, this draft guidance document may be adopted, revised, or withdrawn.

Last Day for Comments: July 8, 2013. 

Q: Are illuminated exit signs with integrated egress lighting or other emergency functions covered by 

Federal energy conservation standards?

A: Yes, the Federal energy conservation standards for illuminated exits signs apply to products with 

integrated egress lighting or other emergency functions (sometimes referred to as combination exit 

signs). However, the standard applies to the exit sign, not to other components (e.g., egress lighting, 

alarms). Manufacturers of these products may require a waiver from the DOE test procedure to test 

and generate representative results for the energy consumption of certain basic models. 

Federal energy conservation standards require that illuminated exit signs manufactured on or after 

January 1, 2006, have an input power demand of 5 watts or less per face. 10 CFR § 431.206; see also

42 U.S.C. § 6295(w). 

DOE understands that certain manufacturers of illuminated exit signs with integrated egress lighting or 

other emergency functions have been operating under a mistaken belief that Federal energy 

conservation standards do not apply to such units. To clarify, any illuminated exit sign that meets each 

element of the relevant product definition1is a covered product under the statute and DOE’s 

 

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The t erm ‘‘illum inat ed exit sign’’ m eans a sign t hat — (A) is d esigned t o b e p erm anent ly f ixed in p lace t o 

id ent if y an exit ; and (B) consist s of an elect rically p ow ered int egral light source t hat — (i) illum inat es t he legend 

‘‘EXIT’’ and any d irect ional ind icat ors; and (ii) p rovid es cont rast b et w een t he legend , any direct ional ind icat ors, 

and t he b ackground. 42 U.S.C. § 6291(37); 10 CFR § 431.202.
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regulations. The addition of ancillary features or hardware would not transform the illuminated exit sign 

into a non-covered product or otherwise move it beyond the applicable regulatory requirements, 

although the added features or hardware are not subject to the energy conservation standard.

DOE recognizes that using the current DOE test procedure to test illuminated exit signs that incorporate

integrated egress lighting or other ancillary features may result in measured values that are not 

representative of solely the illuminated exit sign component’s energy efficiency. In contrast to models 

without ancillary features such as egress lighting, these combination exit sign models must have a larger 

battery capacity to operate the emergency lights for at least 90 minutes after the main power supply is 

disrupted, per National Fire Protection Agency (NFPA) requirements. NFPA 101 § 7.9.2.1. The onboard 

battery charger is an auxiliary power draw that, when charging, typically results in an increase in the

total input power demand beyond the power required to operate the illuminated sign faces alone. 

Because DOE’s current test procedure does not provide a methodology for excluding the power 

consumed for charging the battery used to power features other than the exit sign faces, manufacturers

of basic models with this feature may seek a waiver from the DOE test procedures to test and certify 

these models if they do not believe the result of the DOE test procedure is representative of the exit 

sign’s energy efficiency. Additional details regarding how to obtain a test procedure waiver are available 

in 10 CFR parts 430 (consumer products) and 431 (commercial and industrial equipment).

It is DOE’s enforcement policy to refrain from pursuing an enforcement action while a test procedure 

waiver request is pending. DOE has also initiated a test procedure rulemaking for illuminated exit signs, 

with related rulemaking documents to be subsequently published in the Federal Register and posted on 

the DOE website.