3-i

CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT 

TABLE OF CONTENTS 

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

3.2 SCOPE OF COVERAGE ................................................................................................ 3-1

3.2.1 General Service Fluorescent Lamps .................................................................... 3-1

3.2.1.1 Current CFR Definitions .......................................................................... 3-1

3.2.1.2 Clarification of GSFL Definitions ........................................................... 3-2

3.2.1.3 Additional GSFL Wattages ...................................................................... 3-3

3.2.1.4 Additional GSFL Types ........................................................................... 3-4

3.2.2 Incandescent Reflector Lamps ............................................................................. 3-5

3.3 MARKET ASSESSMENT .............................................................................................. 3-6

3.3.1 Trade Association ................................................................................................ 3-6

3.3.2 Manufacturers and Market Share ......................................................................... 3-7

3.3.2.1 Small Businesses ...................................................................................... 3-8

3.3.3 Regulatory Programs ........................................................................................... 3-9

3.3.3.1 GSFL Federal Energy Conservation Standards ....................................... 3-9

3.3.3.2 IRL Federal Energy Conservation Standards ........................................ 3-10

3.3.3.3 California Energy Commission.............................................................. 3-11

3.3.3.4 Canadian Energy Efficiency Standards ................................................. 3-12

3.3.3.5 European Energy Efficiency Standards ................................................. 3-13

3.3.4 Non-Regulatory Initiatives................................................................................. 3-16

3.3.4.1 Federal Energy Management Program .................................................. 3-16

3.3.4.2 Consortium for Energy Efficiency ......................................................... 3-17

3.3.4.3 Energy Efficient Commercial Building Deduction ................................ 3-17

3.3.4.4 Efficiency Vermont – Agricultural Rebate Program ............................. 3-17

3.3.4.5 Pacific Gas and Electric Company Rebates ........................................... 3-17

3.3.4.6 Northeast Energy Efficiency Partnerships ............................................. 3-18

3.3.4.7 APS Rebate Programs ............................................................................ 3-18

3.3.4.8 Cape Light Compact – Commercial, Industrial and Municipal Buildings 

Energy Efficiency Rebate Program ....................................................... 3-18

3.3.4.9 Central Electric Cooperative – Non-Residential Lighting Rebate ......... 3-19

3.3.4.10 Empire – Commercial and Industrial Energy Efficiency Rebates ...... 3-19

3.3.4.11 GVEA – Residential Rebate Program for Builders ............................ 3-19

3.3.5 Historical Shipments .......................................................................................... 3-19

3.3.5.1 GSFL Shipments .................................................................................... 3-20

3.3.5.2 IRL Shipments ....................................................................................... 3-23

3.4 TECHNOLOGY ASSESSMENT .................................................................................. 3-23

3.4.1 Basic Structure and Operation of General Service Fluorescent Lamps ............. 3-23

3.4.2 GSFL Technology Options ................................................................................ 3-25

3.4.2.1 Highly Emissive Electrode Coatings ..................................................... 3-26

3.4.2.2 Higher Efficiency Lamp Fill Gas Composition ..................................... 3-26

3.4.2.3 Higher Efficiency Phosphors ................................................................. 3-28

3.4.2.4 Glass Coatings ....................................................................................... 3-31

3.4.2.5 Higher Efficiency Lamp Diameter ......................................................... 3-31
3-ii

3.4.2.6 Multi-Photon Phosphors ........................................................................ 3-32

3.4.3 Basic Structure and Operation of Incandescent Reflector Lamps ..................... 3-33

3.4.4 IRL Technology Options ................................................................................... 3-33

3.4.4.1 Higher Temperature Operation .............................................................. 3-34

3.4.4.2 Novel Filament Materials ...................................................................... 3-35

3.4.4.3 Thinner Filaments .................................................................................. 3-35

3.4.4.4 Efficient Filament Placement ................................................................. 3-36

3.4.4.5 Efficient Filament Orientation ............................................................... 3-36

3.4.4.6 Efficient Filament Coiling ..................................................................... 3-36

3.4.4.7 Microcavity Filaments ........................................................................... 3-36

3.4.4.8 Crystallite Filament Coatings ................................................................ 3-36

3.4.4.9 High Reflectance Filament Supports ..................................................... 3-37

3.4.4.10 Higher Efficiency Inert Fill Gas ......................................................... 3-37

3.4.4.11 Higher Pressure Tungsten-Halogen Lamps ........................................ 3-37

3.4.4.12 Non-Tungsten-Halogen Regenerative Cycles..................................... 3-37

3.4.4.13 Infrared Glass Coatings....................................................................... 3-38

3.4.4.14 Higher Efficiency Reflector Coatings ................................................. 3-38

3.4.4.15 Permanent Infrared Reflector Coating Shroud ................................... 3-38

3.4.4.16 Infrared Phosphor Glass Coating ........................................................ 3-39

3.4.4.17 Ultraviolet Phosphor Glass Coating.................................................... 3-39

3.4.4.18 Corner Reflectors ................................................................................ 3-39

3.4.4.19 Electron Stimulated Luminescence..................................................... 3-39

3.4.4.20 Integrally Ballasted Low Voltage Lamps ........................................... 3-39

3.5 PRODUCT CLASSES ................................................................................................... 3-40

3.5.1 General Service Fluorescent Lamps .................................................................. 3-40

3.5.1.1 Physical Constraints of Fluorescent Lamps ........................................... 3-41

3.5.1.2 Lumen Package ...................................................................................... 3-41

3.5.1.3 Diameter ................................................................................................. 3-42

3.5.1.4 Correlated Color Temperature ............................................................... 3-43

3.5.1.5 Ballast Interoperability........................................................................... 3-43

3.5.1.6 Wattage .................................................................................................. 3-43

3.5.1.7 Color Rendering Index ........................................................................... 3-44

3.5.1.8 Product Class Summary ......................................................................... 3-44

3.5.2 Incandescent Reflector Lamps ........................................................................... 3-44

3.5.2.1 Wattage .................................................................................................. 3-45

3.5.2.2 Spectrum ................................................................................................ 3-46

3.5.2.3 Diameter ................................................................................................. 3-46

3.5.2.4 Rated Voltage......................................................................................... 3-46

3.5.2.5 Beam Spread .......................................................................................... 3-47

3.5.2.6 Center Beam Candle Power ................................................................... 3-47

3.5.2.7 Length .................................................................................................... 3-47

3.5.2.8 Product Class Summary ......................................................................... 3-48
3-iii

LIST OF TABLES 

Table 3.3.1 EPAct 1992 Federal Regulations for General Service Fluorescent Lamps .............. 3-9

Table 3.3.2 2009 Lamps Rule Federal Regulations for General Service Fluorescent Lamps ... 3-10

Table 3.3.3 EPAct 1992 Federal Regulations for IRLs ............................................................. 3-10

Table 3.3.4 2009 Lamps Rule Federal Regulations for IRLs .................................................... 3-11

Table 3.3.5 Canadian Energy Efficiency Regulations for Incandescent Reflector Lamps ........ 3-13

Table 3.3.6 EU Minimum Efficacy for T8 and T5 Fluorescent Lamps ..................................... 3-14

Table 3.3.7 EU Deduction Percentages for Efficacy Values for Fluorescent Lamps ................ 3-15

Table 3.3.8 EU Lamp Lumen Maintenance Factors for Fluorescent Lamps ............................. 3-15

Table 3.3.9 EU Deduction Percentages for Fluorescent Lamp Lumen Maintenance Requirements

.................................................................................................................................................... 3-16

Table 3.3.10 EU Lamp Survival Factors for Fluorescent Lamps .............................................. 3-16

Table 3.3.11 NEMA Shipments of Four-Foot Medium Bipin GSFLs ...................................... 3-20

Table 3.3.12 NEMA Shipments of Eight-Foot Single Pin Slimline GSFLs .............................. 3-21

Table 3.3.13 NEMA Shipments of Two-Foot U-Shaped GSFLs .............................................. 3-21

Table 3.3.14 NEMA Shipments of Eight-Foot Recessed Double Contact High Output GSFLs .. 3-

22

Table 3.3.15 NEMA Shipments of Four-Foot T5 Miniature Bipin Standard Output and High 

Output GSFLs ............................................................................................................................ 3-22

Table 3.3.16 NEMA Shipments of IRLs ................................................................................... 3-23

Table 3.5.1 EPAct 1992 Product Classes for General Service Fluorescent Lamps ................... 3-40

Table 3.5.2 GSFL Product Classes from the 2009 Lamps Rule ................................................ 3-40

Table 3.5.3 GSFL Preliminary Analysis Product Classes ......................................................... 3-44

Table 3.5.4 EPAct 1992 Product Classes for Incandescent Reflector Lamps ........................... 3-45

Table 3.5.5 IRL Product Classes from the 2009 Lamps Rule ................................................... 3-45

Table 3.5.6 IRL Preliminary Analysis Product Classes ............................................................. 3-48

LIST OF FIGURES 

Figure 3.4.1 Lamp Length Effects on Efficacy.......................................................................... 3-25

Figure 3.4.2 Lamp Fill Gas Effect on UV Output for T12 Lamps ............................................ 3-27

Figure 3.4.3 Lamp Fill Gas Effect on Thermionic Emission for T12 Lamps ............................ 3-28

Figure 3.4.4 Human Eye Photopic Spectral Luminous Efficiency Function, V(λ) ................... 3-29

Figure 3.4.5 Light Output versus Phosphor Thickness .............................................................. 3-30

Figure 3.4.6 Sample Power Spectrum Distribution ................................................................... 3-30

Figure 3.4.7 Bulb Diameter versus Efficacy .............................................................................. 3-32

Figure 3.4.8 Radiating Characteristics of Tungsten................................................................... 3-34

Figure 3.4.9 Luminous Efficacy versus Color Temperature...................................................... 3-35
3-1

CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

3.1 INTRODUCTION 

 This chapter consists of four sections: scope of coverage, market assessment, the 

technology assessment, and product classes. The scope of coverage describes the products 

covered under this rulemaking and discusses certain amendments to the definitions of these 

products being considered by the U.S. Department of Energy (DOE). 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; 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 class-setting factors DOE considered for this 

rulemaking. 

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. 

3.2 SCOPE OF COVERAGE 

 The following sections describe in more detail the definitions for both general service 

fluorescent lamps (GSFLs) and incandescent reflector lamps (IRLs) that are covered in this 

rulemaking. Further, DOE evaluates clarifications of certain exemptions in the definition of 

“general service fluorescent lamp,” extending standards to additional GSFL types; and including 

additional IRLs in the scope of coverage. 

3.2.1 General Service Fluorescent Lamps 

Section 321 of the Energy Policy and Conservation Act (EPCA; 42 U.S.C. 6291 et seq.) 

contains definitions for fluorescent lamps and associated terms. DOE codified the statutory 

definitions and definitions of supplementary terms for fluorescent lamps in the Code of Federal 

Regulations (CFR). 10 CFR 430.2. These definitions are provided below and also listed in 

appendix 3A of this preliminary technical support document (TSD). 

3.2.1.1 Current CFR Definitions 

10 CFR 430.2 defines a fluorescent lamp and general service fluorescent lamp as follows: 

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 bases of nominal overall length of 96 inches; 
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(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. 

General service fluorescent lamp means any fluorescent lamp which can be used to satisfy 

the majority of fluorescent lighting applications, but does not include any lamp designed and 

marketed for the following nongeneral application: 

(1) Fluorescent lamps designed to promote plant growth; 

(2) Fluorescent lamps specifically designed for cold temperature applications; 

(3) Colored fluorescent lamps; 

(4) Impact-resistant fluorescent lamps; 

(5) Reflectorized or aperture lamps; 

(6) Fluorescent lamps designed for use in reprographic equipment; 

(7) Lamps primarily designed to produce radiation in the ultra-violet region of the 

spectrum; and 

(8) Lamps with a Color Rendering Index of 87 or greater. 

10 CFR 430.2 

3.2.1.2 Clarification of GSFL Definitions 

DOE received several queries from the general public on the application of the 

exemptions listed in the GSFL definition. DOE is considering whether further clarity should be 

provided for these exemptions. DOE evaluated each one and found that “impact-resistant 

fluorescent lamps” and “reflectorized or aperture lamps” were the only two exemptions and “use 

in reprographic material” and “the ultra-violet region of the spectrum” were the only two terms 

not defined elsewhere or the application of the exemption was not clearly stated. For example, 

“colored fluorescent lamps” are already defined separately within the CFR and “fluorescent 

lamps designed to promote plant growth” clearly specifies the function of the lamps such that 

their identification is unambiguous. To provide further clarification on the terms “impactresistant,” “reflectorized or aperture,” “reprographic equipment,” and “ultra-violet region of the 

spectrum,” DOE examined industry bulletins, product literature, and other online publications. 

Through this research and manufacturer interviews, DOE has found “impact-resistant” to be 

synonymous with “shatter-resistant” and is considering a definition for “impact-resistant 

fluorescent lamp” based on the existing definition of “shatter-resistant lamp” in 10 CFR 430.2 as 

follows: 

Impact-resistant fluorescent lamp means a lamp that: 

a. Has a coating or equivalent technology that is compliant with NSF/ANSI 51 

(incorporated by reference; see §430.3) and is designed to contain the glass if the 

glass envelope of the lamp is broken; and 

b. Is designated and marketed for the intended application, with 

i. The designation on the lamp packaging; and 
3-3

ii. Marketing materials that identify the lamp as being impact-resistant, 

shatter-resistant, shatter-proof, or shatter-protected.

Product literature, industry bulletins, and online publications indicated that “reflectorized 

or aperture lamp” refers to lamps that contain an inner reflective coating on the bulb to direct 

emitted light. Therefore, DOE is considering defining “reflectorized or aperture lamp” as 

follows: 

Reflectorized or aperture lamp means a fluorescent lamp that contains an inner reflective 

coating on the bulb to direct the light. 

 Addtionally, DOE is considering adding more detail for “use in reprographic material” 

and “the ultra-violet region of the spectrum” to provide a better understanding of DOE’s

interpretation of these terms. DOE has found that “fluorescent lamp[s] designed for use in 

reprographic equipment” are intended for use in equipment that is used to reproduce, reprint, or 

copy graphic material. Therefore, DOE is considering defining “fluorescent lamps designed for 

use in reprographic equipment” as follows: 

Fluorescent lamps designed for use in reprographic equipment means fluorescent lamps 

incorporated in equipment used to reproduce, reprint, or copy graphic material. 

 Concerning “lamps primarily designed to produce radiation in the ultra-violet region of 

the spectrum,” DOE determined that the term “ultra-violet region of the spectrum” refers to the 

portion of the electromagnetic spectrum where light has a wavelength between 10 and 400 

nanometers. Therefore, DOE is considering adding detail to the exemption as follows: 

Lamps primarily designed to produce radiation in the ultra-violet region of the spectrum

mean fluorescent lamps that primarily emit light in the portion of the electromagnetic 

spectrum where light has a wavelength between 10 and 400 nanometers. 

DOE is also considering clarification of references to “designed” and “marketed” as 

applied to definitions of lighting products covered under DOE standards. These terms are 

generally used to restrict lamps to use in certain intended applications and/or functions and to 

limit potential loopholes. Therefore, DOE is considering the terms “designed,” “designated,” 

“designation,” “designated and marketed,” and “designed and marketed” for covered lighting 

products to mean that in a publicly available document (e.g., product literature, catalogs, labels), 

manufacturers explicitly state the application for which the lamp is intended.

Please see chapter 2 of this TSD for more discussion on DOE’s consideration of 

additional fluorescent lamps and its interpretation of EPCA’s definitions.

3.2.1.3 Additional GSFL Wattages 

In its review of the market, DOE determined that there are fluorescent lamps with lower 

wattages than those specified in DOE’s definition. Specifically, DOE found lower wattage lamps 

for the 8-foot single pin (SP) slimline, 4-foot T5 miniature bipin (MiniBP) standard output (SO), 

and 4-foot T5 MiniBP high output (HO) lamp types. DOE currently covers 8-foot SP slimline 
3-4

lamps with wattages of 52 W or more. The 8-foot SP slimline lamps are now being offered in 

lower wattages of 49 W, 50 W, and 51 W. DOE currently covers 4-foot T5 MiniBP SO lamps 

with wattages of 26 W or more. The 4-foot T5 MiniBP SO lamps are now being offered at a 

lower wattage of 25 W. DOE currently covers 4-foot T5 MiniBP HO lamps with wattages of 49 

W or more. The 4-foot T5 MiniBP HO lamps are now being offered at lower wattages of 44 W 

and 47 W. These reduced-wattage lamps are generally more efficacious than their full wattage 

counterparts and, because of their lower wattage, offer the potential for increased energy savings. 

Further, manufacturer feedback indicated that the lower wattage lamp market will only grow in 

size. Therefore, DOE is considering extending coverage to the following GSFLs: 

 8-foot SP slimline lamps with wattages ≥ 49 W and < 52 W; 

 4-foot MiniBP SO lamps with wattages ≥ 25 W and < 26 W; and

 4-foot MiniBP HO lamps with wattages ≥ 44 W and < 49 W. 

3.2.1.4 Additional GSFL Types 

As part of this energy conservation standards rulemaking, DOE is directed to evaluate 

energy efficiency standards for additional GSFLs beyond those already covered. 42 U.S.C. 6295 

(i)(5) To identify the potential additional GSFLs, DOE first reviewed the fluorescent lighting 

market and identified lamps that meet the general description of a “fluorescent lamp” in the 

introductory language of 42 U.S.C. 6291(30)(A), that can be used to satisfy the majority of 

fluorescent lighting applications, that are not within the exclusions specified in 42 U.S.C. 

6291(30)(B), and for which EPCA does not already prescribe standards. 73 FR 13629, 13620 

(March 13, 2008). For each additional GSFL identified, DOE then assessed whether standards 

for such lamps would result in significant energy savings and, further, if such standards are 

technologically feasible and economically justified. Standards for any applicable additional 

GSFL are adopted based on the same criteria used to set new or amended standards for products 

per 42 U.S.C. 6295(o). 

Fluorescent lamps come in three primary shapes: linear, U-shaped, and circline. Current 

standards cover certain linear and U-shaped lamps. There is little publicly available information 

on the installed stock and energy consumption of circline lamps. The 2010 U.S. Lighting Market 

Characterization (LMC) report includes these lamps under the miscellaneous category for 

fluorescent lamps, which composed 2.1 percent of lighting and consumed 4 terrawatt-hour 

(TWh) of electricity in 2010.a Circline lamps would only be a small portion of the installed stock 

and energy consumption of this category, which includes all fluorescents other than T5 linear 

and T8 and T12 linear and U-shaped lamps, as well as fluorescent lamps with unknown 

characteristics. The low levels of installed stock and energy consumption for these alternateshaped fluorescent lamps indicate limited potential for energy savings. Additionally, feedback 

from manufacturer interviews confirmed that fluorescent lamps in shapes not covered do not 

comprise a significant portion of the market. Based on this analysis DOE is not considering 

extending coverage to fluorescent lamps with shapes not currently covered. 

 

a

 U.S. Department of Energy. 2010 U.S. Lighting Market Characterization. January 2012. Available at 

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf. 
3-5

DOE’s assessment of linear fluorescent lamps with lengths not covered shows that 

standards for these lamp types would not likely result in significant energy savings. Linear 

medium bipin (MBP) lamps come in lengths ranging from 1 to 6 feet and are mainly T8 and T12 

diameters. Currently only 4-foot MBP linear lamps are covered by standards. DOE’s analysis 

shows that 5- and 6-foot linear fluorescent lamps compose a very low percentage of the linear 

MBP product offerings. For the T8 MBP lamps with lengths less than 4 feet, according to the 

2010 LMC, these lamps composed about 0.2 percent of all installed lighting and consumed 1 

TWh of electricity in 2010.b

The installed inventory of T12 MBP lamps with lengths less than 4 

feet is even less than the T8 lamps. The low levels of installed stock and energy consumption of 

these lamps indicate limited potential for energy savings. Further, in interviews manufacturers 

confirmed that linear fluorescent lamps with alternate lengths do not represent a significant 

portion of the market. Based on this analysis, DOE is not considering extending coverage to 

linear fluorescent lamps with lengths not currently covered. 

Additionally, DOE determined that compact fluorescent lamps (CFLs) are included in the 

“general service lamps” definition, which also mentions general service incandescent lamps, 

general service light-emitting diode lamps, and organic light-emitting diode lamps, but excludes 

any general service fluorescent lamp. DOE has determined that the term “compact fluorescent 

lamps” in this definition includes both pin base and medium base CFLs. Under 42 U.S.C. 

6295(i)(6), DOE is required to initiate a rulemaking for general service lamps no later than 

January 2014. This requirement indicates that it was intended for DOE to establish standards for 

lamps categorized as general service lamps, including CFLs, in a rulemaking separate from 

GSFLs. Therefore, DOE has determined that CFLs do not fall within the scope of this 

rulemaking. 

3.2.2 Incandescent Reflector Lamps 

 As with GSFLs, DOE codified the statutory definitions and definitions of supplementary 

terms for IRLs in the CFR. The definition of “incandescent reflector lamp” contains several 

terms that limit the scope of IRLs. Appendix 3A of this TSD contains statutory and CFR 

definitions for many of these terms. 10 CFR 430.2 defines an incandescent reflector lamp as:

Incandescent reflector lamp (commonly referred to as a reflector lamp) means any lamp 

in which light is produced by a filament heated to incandescence by an electric current, 

which: is not colored or designed for rough or vibration service applications that contains 

an inner reflective coating on the outer bulb to direct the light; has an R, PAR, ER, BR, 

BPARc

, or similar bulb shapes with an E26 medium screw base; has a rated voltage or 

voltage range that lies at least partially in the range of 115 and 130 volts; has a diameter 

that exceeds 2.25 inches; and has a rated wattage that is 40 watts or higher. 

 

b

 U.S. Department of Energy. 2010 U.S. Lighting Market Characterization. January 2012. Available at 

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf. 

c

 Lamp shapes: R (reflector), PAR (parabolic aluminized reflector), ER (elliptical reflector); BR (bulged reflector), 

BPAR (bulged parabolic aluminum reflector) 
3-6

 Certain reflector (R), elliptical reflector (ER), and bulged reflector (BR) IRLs are covered 

by this definition but are not included in this rulemaking. Section 322(b) of EISA 2007, in 

amending EPCA to set forth revised standards for IRLs in new section 325(i)(1)(C), exempted 

from these standards the following categories of IRLs: (1) lamps rated 50 watts or less that are 

ER30, BR30, BR40, or ER40; (2) lamps rated 65 watts that are BR30, BR40, or ER40 lamps; 

and (3) R20 incandescent reflector lamps rated 45 watts or less. (42 U.S.C. 6295(i)(C)) (DOE 

refers to these three categories of lamps collectively as “certain R, ER, and BR IRLs.”) DOE 

subsequently determined that this EISA 2007 amendment exempted these lamps from 

regulations that existed at that time but did not preclude them from future regulations. However, 

because the rulemaking process for the first cycle of amendments to GSFL and IRL standards 

per 42 U.S.C. 6295(i)(5) (hereafter “2009 Lamps Rule”)d was already underway, DOE decided 

to initiate a separate rulemaking for these certain R, ER, and BR IRLs. Therefore, DOE is not 

considering amending standards for these products in this rulemaking. (See chapter 2 of the TSD 

for further discussion.) 

With respect to wattage, while the definition requires IRLs to have a “rated wattage that 

is 40 watts or higher,” current IRL standards are set for the 40-205 W range. DOE assessed this 

upper limit of the wattage range for covered IRLs. Based on a review of manufacturer catalogs, 

DOE determined that IRLs with rated wattages greater than 205 W compose a very small portion 

of the market and, therefore, do not represent substantial potential energy savings. Furthermore, 

many of these products are designed for specialty uses such as heating and drying in industrial 

and commercial applications, or for use in swimming pools. For these reasons, DOE is not 

considering coverage for IRLs with rated wattages greater than 205 W.

3.3 MARKET ASSESSMENT 

For both GSFLs and IRLs, the following market assessment identifies the relevant 

manufacturer trade association and domestic manufacturers; discusses manufacturer market 

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

historical shipment data. 

3.3.1 Trade Association 

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

GSFLs and IRLs. NEMA’s Lighting Systems Division is one of ten product divisions, and is 

further divided into six product sections. The Lamp Section’s 27 member companies compose, 

according to manufacturer interviews, about 90 percent of the U.S. GSFL and IRL markets. In 

addition to GSFLs and IRLs, NEMA’s Lighting Systems Division also oversees products such as 

ballasts, 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 businesses. 

NEMA’s activities relating to energy efficiency include:1

 

d

 The final rule for this first cycle of amendments to GSFL and IRL standards was published in July 2009. 74 FR 

34080 (July 14, 2009). 
3-7

 “[a]dvising the U.S. Department of Energy (DOE) and U.S. Environmental Protection 

Agency (EPA) 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; 

 supporting adoption of ASHRAE/IESNA 90.1 lighting provisions; 

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

energy-efficient lighting technologies; 

 advising DOE and 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.” 

3.3.2 Manufacturers and Market Share 

 The following list contains the names of manufacturers that produce GSFLs: 

 Atlas Lighting Products, Inc. 

 Bulbrite Industries, Inc. 

 EiKO, Ltd. 

 Feit Electric Company, Inc. 

 GE Consumer & Industrial 

 Halco Lighting Technologies 

 Havells USA

 Litetronics International, Inc. 

 MaxLite 

 OSRAM SYLVANIA Inc. 

 OttLite Technologies Inc. 

 Philips Lighting Company 

 Plusrite Electric (China) Co., Ltd. 

 Satco Products, Inc. 

 SLI Lighting 

 Technical Consumer Products, Inc. 

 Topaz Lighting Corp. 

 Universal Lighting Technologies 

 Ushio America, Inc. 

 Westinghouse Lighting Corporation 

 The following list contains the names of manufacturers that produce IRLs: 

 Advanced Lighting Technologies Inc. 

 Bulbrite Industries, Inc. 

 EiKO, Ltd. 

 EYE Lighting International of N.A., Inc. 

 Feit Electric Company, Inc. 
3-8

 GE Consumer & Industrial 

 Green Energy Lighting Corp. 

 Halco Lighting Technologies 

 Havells USA 

 Howard Industries Inc. 

 Litetronics International, Inc. 

 OSRAM SYLVANIA Inc. 

 Philips Lighting Company 

 Premium Quality Lighting, Inc. 

 RAB Lighting 

 Satco Products, Inc. 

 SLi Lighting 

 Technical Consumer Products, Inc. 

 Ushio America, Inc. 

 Venture Lighting International 

 Westinghouse Lighting Corporation 

 The GSFL and IRL industries are characterized by both domestic and international 

manufacturers. The majority of covered GSFLs and IRLs are manufactured by three large 

companies. The three manufacturers that hold the majority of the domestic market share of 

GSFLs and IRLs are the following: 

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

 OSRAM SYLVANIA of Siemens AG (hereafter “OSI”)

 Philips Lighting Company of Philips Electronics North America Corporation (hereafter 

“Philips”) 

 In addition to lamps listed under this rulemaking, the lighting divisions of all three 

companies manufacture other products, such as ballasts, high intensity discharge lamps, lightemitting diodes (LEDs), and CFLs.

3.3.2.1 Small Businesses 

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

conservation standards for GSFLs and IRLs. 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 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 

lamps, the size standard is matched to NAICS code 335110, Electric Lamp Bulb and Part 

Manufacturing, which has a size standard of 1,000 employees or fewer.2

 DOE studies the potential impacts on these small businesses in detail as part of the 

manufacturer impact analysis. 
3-9

3.3.3 Regulatory Programs 

 Several federal and international regulatory programs affect the markets for GSFLs and 

IRLs. The following section summarizes U.S., Canadian, and European regulatory initiatives 

relevant to the lamps covered by this rulemaking. While the following discussion is not 

exhaustive in describing all regulatory action related to GSFLs and IRLs, it provides detail on 

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

3.3.3.1 GSFL Federal Energy Conservation Standards 

 EPCA 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 GSFLs. Specifically, the Energy Policy Act of 1992 (EPAct 

1992), Pub. L. 102-486, established energy conservation standards for 4-foot MBP, 2-foot Ushaped, 8-foot SP slimline, and 8-foot recessed double contact (RDC) HO GSFLs. The standards 

mandate that lamps manufactured on or after the specified effective dates must meet the 

minimum color rendering index (CRI) and minimum average lamp efficacy requirements. (42 

U.S.C. 6295(i)(1)); 10 CFR Section 430.32(n)(1) Table 3.3.1 presents these Federal standards. 

Table 3.3.1 EPAct 1992 Federal Regulations for General Service Fluorescent Lamps 

Lamp Type

Nominal Lamp 

Wattage

W

Minimum 

CRI

Minimum Average Lamp 

Efficacy

lm/W

Effective 

Date

4-foot medium 

bipin

> 35 W 69 75.0 Nov. 1, 1995

≤ 35 W 45 75.0 Nov. 1, 1995

2-foot U-shaped > 35 W 69 68.0 Nov. 1, 1995

≤ 35 W 45 64.0 Nov. 1, 1995

8-foot slimlinee > 65 W 69 80.0 May 1, 1994

≤ 65 Wf45 80.0 May 1, 1994

8-foot high output > 100 W 69 80.0 May 1, 1994

≤ 100 W 45 80.0 May 1, 1994

 EPCA directs DOE to conduct two cycles of rulemakings to determine whether to amend 

GSFL standards, and to determine whether to adopt standards for additional types of GSFLs. (42 

U.S.C. 6295(i)(3)–(5)) Today’s rulemaking represents the second rulemaking to evaluate 

amending the GSFL energy conservation standards. The first rulemaking, the 2009 Lamps Rule, 

resulted in a final rule published in the Federal Register on July 14, 2009, which, as directed by 

42 U.S.C. 6295(i)(3), altered EPAct 1992 standards and, as directed by 42 U.S.C. 6295(i)(5), 

also adopted energy conservation standards for additional GSFLs. 74 FR 34080. The 2009 

Lamps Rule adopted the lamp efficacy standards shown in Table 3.3.2 for GSFLs manufactured 

after July 14, 2012. 10 CFR Section 430.32(n)(3) 

 

e

 Shown correctly in this table; as written in the CFR, the ≤ 35W class was misattributed to 8-foot slimline lamps. 

f

 Shown correctly in this table; as written in the CFR, “˃ 65W” is erroneously repeated in this cell. 
3-10

Table 3.3.2 2009 Lamps Rule Federal Regulations for General Service Fluorescent Lamps 

Lamp Type Correlated Color Temperature

Minimum Average Lamp

Efficacy

lm/W

4-foot medium bipin ≤4,500 K 89

>4,500 K and ≤7,000 K 88

2-foot U-shaped ≤4,500 K 84

>4,500 K and ≤7,000 K 81

8-foot slimline ≤4,500 K 97

>4,500 K and ≤7,000 K 93

8-foot high output ≤4,500 K 92

>4,500 K and ≤7,000 K 88

4-foot miniature bipin 

standard output

≤4,500 K 86

>4,500 K and ≤7,000 K 81

4-foot miniature bipin 

high output

≤4,500 K 76

>4,500 K and ≤7,000 K 72

3.3.3.2 IRL Federal Energy Conservation Standards 

 As with GSFLs, amendments to EPCA in EPAct 1992 established energy conservation 

standards for IRLs. (42 U.S.C. 6291(1) and 42 U.S.C. 6295(i)(1)) In addition, subsequent 

amendments to EPCA in the Energy Independence and Security Act of 2007 (EISA 2007), Pub.

L. 110-140, amended the existing standards for IRLs. Table 3.3.3 outlines these amended 

standards. EPCA mandated that all lamps manufactured after November 1, 1995 meet six 

efficacy requirements with minimum lamp efficacy varying by nominal lamp wattage. EISA 

2007 amended EPCA’s definition for IRL and amended the standard in 42 U.S.C. 6295(i)(1). 

Prior to EISA 2007, the statutory definition for IRLs excluded ER- and BR-shaped lamps and 

lamps with a diameter less than 2.75 inches. EISA 2007 amended this definition to include ERand BR-shaped lamps and lamps with diameters greater than 2.25 inches. EISA 2007 also 

amended 42 U.S.C. 6295(i)(1) to exempt the following lamps from the minimum efficacy 

requirements: (1) lamps rated at 50 watts or less that are ER30, BR30, BR40, and ER40; (2) 

lamps rated at 65 watts that are BR30, BR40, or ER40 lamps; and (3) R20 incandescent reflector 

lamps rated 45 watts or less. 

Table 3.3.3 EPAct 1992 Federal Regulations for IRLs 

Nominal Lamp Wattage

W

Minimum Average Lamp Efficacy

lm/W

40-50 10.5

51-66 11.0

67-85 12.5

86-115 14.0

116-155 14.5

156-205 15.0

 Along with GSFL standards, EPCA directs DOE to conduct two cycles of rulemakings to 

determine whether to amend IRL standards. (42 U.S.C. 6295(i)(3)–(5)) Today’s rulemaking 

represents the second rulemaking to evaluate amending the IRL energy conservation standards. 
3-11

The first rulemaking, the 2009 Lamps Rule, resulted in a final rule that, as directed by 42 U.S.C. 

6295(i)(3), amended EPAct 1992 standards for covered IRLs manufactured after July 14, 2012, 

as shown in Table 3.3.4. 10 CFR Section 430.32(n)(5) 

Table 3.3.4 2009 Lamps Rule Federal Regulations for IRLs 

Rated Lamp 

Wattage Lamp Spectrum Lamp Diameter

inches Rated Voltage

Minimum Average 

Lamp Efficacy

lm/W

40–205 Standard Spectrum

>2.5

≥125 V 6.8*P0.27

<125 V 5.9*P0.27

≤2.5

≥125 V 5.7*P0.27

<125 V 5.0*P0.27

40–205 Modified Spectrum

>2.5

≥125 V

g

5.8*P0.27

<125 V 5.0*P0.27

≤2.5

≥125 V 4.9*P0.27

<125 V 4.2*P0.27

Note 1: P is equal to the rated lamp wattage, in watts.

Note 2: Standard Spectrum means any incandescent reflector lamp that does not meet the definition of 

modified spectrum in 430.2.

3.3.3.3 California Energy Commission 

California’s Office of Administrative Law (OAL) enacts statewide regulatory programs 

published in the California Code of Regulations (CCR). CCR Title 20, Division 2, Chapter 4, 

Article 4, Section 1605.3 contains state regulations for IRLs in accordance with the WarrenAlquist State Energy Resources Conservation and Development Act, last revised in May 2012. 

This law requires that lighting standards be set to achieve a 50 percent reduction in energy 

consumption from 2007 levels for indoor residential lighting and a 25 percent reduction from 

2007 levels for indoor commercial and outdoor lighting by 2018. Current CCR standards for 

IRLs are identical to EPAct 1992 standards including the EISA 2007 exemptions. 

CCR Title 24, Part 6 contains the 2013 Building Energy Efficiency Standards, Section 

110.9 of which mandates requirements for lighting control devices and systems, ballasts, and 

luminaires. These regulations were approved in May 2012 and go into effect on January 1, 2014, 

replacing the 2008 Building Energy Efficiency Standards. The 2013 Building Energy Efficiency 

Standards are 25 percent more efficient than the previous standards for residential construction 

and 30 percent more efficient for non-residential construction.3

Products regulated by Title 24 

include those that can be used with GSFLs and IRLs, such as automatic time-switch control 

devices, occupancy sensors, multilevel occupancy sensors, automatic daylighting control 

devices, interior photosensors, multilevel and outdoor astronomical time-switch controls, 

 

g

 Shown correctly in this table; erroneously written as “≤125V” in the CFR. See chapter 2 for further discussion. 
3-12

manual-on occupancy sensors, dimmers, integral current limiters, ballasts for residential recessed 

luminaires, and dimming fluorescent ballasts. The regulations mandate that the products have 

specific features and capabilities in order to be installed. 

3.3.3.4 Canadian Energy Efficiency Standards 

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

energy efficiency of GSFLs and IRLs in Canada.h

 In 1992, the Canadian Parliament passed the 

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

energy-using products, effective February 1995. In November 1995, Canada’s Energy Efficiency 

Regulations (SOR/94-651) were amended to include GSFLs and IRLs. 

 Canada’s approach to the regulation of GSFLs closely resembles the U.S. Federal 

Efficiency Standards established by EPAct 1992 discussed in section 3.3.3.1. Though there are 

minor variations in definitions between the U.S. and Canadian standards, they effectively cover 

the same product. The Canadian minimum average CRI and lamp efficacy levels for GSFLs 

established in the 1995 amendments are identical to those shown in Table 3.3.1. In May 2010, 

NRCan published a bulletin proposing amendments to the regulations in order to modify GSFL 

definitions and to harmonize standards with the 2009 Lamps Rule, with the proposed 

amendments applying to those products manufactured on or after July 14, 2012. At the time of 

this analysis these proposed amendments had not been adopted. 

 Regarding IRLs, the 1995 amendments to SOR/94-651 included general service IRLsi

with minimum performance requirements consistent with EPAct 1992. However, differing 

slightly from the U.S. approach, an amendment in April 2003 revised the Regulations to include 

certain ER and BR IRLs. Specifically, NRCan amended the Regulations to apply to general 

service IRLs with: 

 an R, PAR, BR, ER or bulb shape similar to R, PAR, BR or ER as described by ANSI 

C79.1; 

 an E26/24 single contact, or E26/50x39 skirted, medium screw base; 

 a nominal voltage or voltage range that lies at least partially between 100 and 130 V; 

 

h

 News and information on NRCan energy efficiency regulations and standards can be found at 

http://oee.nrcan.gc.ca/regulations/11239. 

i

 The current definition of “general service incandescent reflector lamp” in SOR/94-651 is as follows: 

“general service incandescent reflector lamp” means an incandescent reflector lamp with a bulb shape as 

described in ANSI C79.1 or similar shape that has 

(a) an E26/24 single contact or E26/50 × 39 skirted, medium screw base, 

(b) a nominal voltage or voltage range that lies at least partially between 100 V and 130 V, 

(c) a diameter greater than 57 mm, and 

(d) a nominal power of not less than 40 W and not more than 205 W; 

but does not include 

(e) a coloured lamp, 

(f) a BR30 lamp or BR40 lamp with a nominal power of up to 50 W, or 65 W, 

(g) a R20 lamp with a nominal power of not more than 45 W, 

(h) a silver bowl lamp, or 

(i) a lamp for heat-sensitive applications” 
3-13

 a diameter greater than 70 mm (2.75 in.); and 

 a nominal power of not less than 40 W and not more than 205 W. 

The amendment also exempted BR30 lamps of 66 W or less; 85 W BR30 lamps and 

BR38 to BR40 lamps with a rated power of less than 121 W. In October 2011, NRCan published 

an amendment to the existing Regulations to harmonize with EISA 2007; the amendment came 

into force April 12, 2012. 

In April 2010, NRCan had proposed an amendment to harmonize with the 2009 Lamps 

Rule. NRCan’s amendment was proposed to become effective July 14, 2012. In November 2011, 

NRCan revised the definition of IRLs in the April 2010 proposed amendment to match the 

definition ultimately published in the October 2011 amendment. At the time of this analysis this 

proposed amendment had not been adopted. The current Canadian Regulations are shown in 

Table 3.3.5. 

Table 3.3.5 Canadian Energy Efficiency Regulations for Incandescent Reflector Lamps 

Rated Wattage

W

Minimum Average Efficacy

lm/W

ER30 or ER40 IRLs

≤ 50 7.0

Other ER IRLs

50 7.0

75 6.5

120 10.0

All Other Covered IRLs

40-50 10.5

51-59 11.0

60-85 12.5

86-115 14.0

116-155 14.5

156-205 15.0

3.3.3.5 European Energy Efficiency Standards 

Commission Regulation (EU) No 347/2010 (April 21, 2010) amended Commission 

Regulation (EC) No 245/2009 (March 18, 2009), which implemented Directive 2005/32/EC 

(July 6, 2005) of the European Parliament and the Council of the European Union and amended 

Council Directive 92/42/EEC and Directives 96/57/EC and 2000/55/EC (September 18, 2000) to 

establish a framework for setting energy efficiency requirements for energy-using equipment, 

including fluorescent lamps and the ballasts and luminaires that are used with these lamps. The 

energy efficiency requirements apply to equipment available on the market and do not 

differentiate requirements by lamp application. Lamps that are not white light sources, are 

directional, or intended for use in applications other than general lighting are exempted from 

standards. Additionally, the EU exempts lamps having: 

 Six percent or more of total radiation of the range 250-780 nm in the range of 250-

400 nm; 

 Eleven percent of total radiation of the range 250-780 nm in the range of 630-780 nm; 
3-14

 Five percent or more of total radiation of the range 250-780 nm in the range of 640-

700 nm; and 

 The peak of the radiation between 315-400 nm or 280-315 nm. 

The EU also exempts double-capped fluorescent lamps having: 

 A diameter of 7 mm (T2) and less; 

 A diameter of 16 mm (T5) and lamp power P ≤ 13 W or P ˃ 80 W; 

 A diameter of 38 mm (T12), lamp cap G-13 medium bipin (MBP) base, +/- 5 m color 

compensating filter value limit (cc). International Commission on Illumination 

coordinates x = 0.330, y = 0.335 and x = 0.415, y = 0.377; and 

 A diameter of 38 mm (T12) and equipped with an external ignition strip.4 5

The European energy efficiency requirements regulate the covered equipment in stages. 

First stage requirements began in 2010 and required double-capped fluorescent lamps of 16mm 

and 26mm (i.e., T5 and T8 lamps) without integrated ballasts to comply with the efficacies listed 

in Table 3.3.6 at 25 °C. Second stage requirements begin in 2013, requiring double-capped 

fluorescent lamps of other diameters than those covered in the first stage to meet the minimum 

efficacy requirement for T8 lamps given in the first stage. Third stage requirements begin in 

2018, requiring minimum compatible ballast efficiencies for all fluorescent lamps without an 

integrated ballast. 

Table 3.3.6 EU Minimum Efficacy for T8 and T5 Fluorescent Lamps 

T8 (26 mm Ø) T5 (16 mm Ø)

High Efficiency

T5 (16 mm Ø)

High Output

Nominal wattage 

(W)

Rated luminous 

efficacy (lm/W), 

100 h initial 

value

Nominal wattage 

(W)

Rated luminous 

efficacy (lm/W) 

100 h initial 

value

Nominal wattage 

(W)

Rated luminous 

efficacy (lm/W), 

100 h initial 

value

15 63 14 86 24 73

18 75 21 90 39 79

25 76 28 93 49 88

30 80 35 94 54 82

36 93 80 77

38 87

58 90

70 89

Source: 245/2009/EC 

2010/347/EU amended the efficacy deductions given in 2009/245/EC for fluorescent 

lamps with high color temperature, high color rendering, second lamp envelope, or long life, so 

that required efficacy is cumulatively reduced as shown in Table 3.3.7. 
3-15

Table 3.3.7 EU Deduction Percentages for Efficacy Values for Fluorescent Lamps 

Lamp parameter Deduction from luminous efficacy at 25 °C

Tc ≥ 5,000 K -10%

95 ≥ Ra > 90 -20%

Ra > 95 -30%

Second lamp envelope -10%

Lamp Survival Factor ≥ 0.50 after 40,000 burning hours -5%

Source: 2010/347/EU 

In addition to lamp efficacy, the EU standards contain requirements for lamp 

performance, including lamp lumen maintenance factor (LLMF) and lamp survival factor (LSF). 

The LLMF describes how bright a lamp remains as a percentage of the original brightness after a 

given period of time, while the LSF describes how long a lamp lasts before ceasing to function 

and requiring replacement, and is expressed as a percentage of the number of lamps still working 

after a specified period of time. 2010/347/EU amended the LLMF and LSF requirements given 

in 2009/245/EC, and added cumulative LLMF deductions for certain lamps. Under current 

standards, for the first stage requirements, T5 and T8 lamps must have a minimum 80 CRI. For 

the second stage requirements, all covered fluorescent lamps without an integrated ballast must 

have a minimum CRI of 80, an LLMF as shown in Table 3.3.8 and Table 3.3.9, and an LSF as 

shown in Table 3.3.10. 

Table 3.3.8 EU Lamp Lumen Maintenance Factors for Fluorescent Lamps 

Lamp lumen maintenance factor Burning hours

Lamp types 2,000 4,000 8,000 16,000

Double-Capped Fluorescent lamps operating on non-high 

frequency ballasts 0.95 0.92 0.90 --

T8 Double-Capped Fluorescent lamps on high frequency 

ballast with warmstart 0.96 0.92 0.91 0.90

Other Double-Capped Fluorescent lamps on high frequency 

ballast with warmstart 0.95 0.95 0.90 0.90

Circular Single-Capped Fluorescent lamps operating on 

non-high frequency ballasts, T8 U-shaped double-capped 

fluorescent lamps and spiral-shaped double-capped 

fluorescent lamps of all daimeters equal to or larger than 16 

mm (T5)

0.80 0.74 -- --

0.72 at 5,000 burning hours

Circular Single-Capped Fluorescent lamps operating on 

high frequency ballasts

0.85 0.83 0.80 --

0.75 at 12,000 burning hours

Other Single-Capped Fluorescent lamps operating on nonhigh frequency ballasts 0.85 0.78 0.75 --

Other Single-Capped Fluorescent lamps operating on high 

frequency ballast with warmstart 0.90 0.84 0.81 0.78

Source: 2010/347/EU 
3-16

Table 3.3.9 EU Deduction Percentages for Fluorescent Lamp Lumen Maintenance 

Requirements 

Lamp parameter Deduction from lamp lumen maintenance requirement

Lamps with 95 ≥ Ra > 90 At burning hours ≤ 8,000 h: -5%

At burning hours > 8,000 h: -10%

Lamps with Ra > 95 At burning hours ≤ 4,000 h: -10%

At burning hours > 4,000 h: -15%

Lamps with a colour temperature ≥ 5,000 K -10%

Source: 2010/347/EU 

Table 3.3.10 EU Lamp Survival Factors for Fluorescent Lamps 

Lamp survival factor Burning hours

Lamp types 2,000 4,000 8,000 16,000

Double-Capped Fluorescent lamps operating on non-high 

frequency ballasts 0.99 0.97 0.90 --

Double-Capped Fluorescent lamps on ghihg frequency 

ballast with warmstart 0.99 0.97 0.92 0.90

Circular Single-Capped Fluorescent lamps operating on nonhigh frequency ballasts, T8 U-shaped double-capped 

fluorescent lamps and spiral-shaped double-capped 

fluorescent lamps of all diameters equal to or larger than 16 

mm (T5)

0.98 0.77 -- --

0.50 at 5,000 burning hours

Circular Single-Capped Fluorescent lamps operating on high 

frequency ballasts

0.99 0.97 0.85 --

0.50 at 12,000 burning hours

Other Single-Capped Fluorescent lamps operating on nonhigh frequency ballasts 0.98 0.90 0.50 --

Other Single-Capped Fluorescent lamps on high frequency 

ballast with warmstart 0.99 0.98 0.88 --

Source: 2010/347/EU 

3.3.4 Non-Regulatory Initiatives 

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

use of energy efficient lighting in the United States. The following section summarizes these 

programs for the lamps 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. 

3.3.4.1 Federal Energy Management Program 

The Federal Energy Management Program (FEMP) helps Federal buyers identify and 

purchase energy efficient products including certain GSFLs. Section 161 of EPAct 1992 

encourages energy efficient Federal procurement. Executive Order 12902 and FAR section 

23.704 direct agencies to purchase products in the upper 25 percent of energy efficiency. FEMP 

typically provides recommendations of total light output (in lumens) and the best available 

models of fluorescent lamps. However, at the time of publishing, FEMP has temporarily 

suspended its energy efficiency requirements for fluorescent lamps as it evaluates the market 

impact of the standards adopted by the 2009 Lamps Rule (hereafter “the July 2012 standards”). 

The program will issue updated energy efficiency requirements when the GSFL market 

distribution stabilizes. FEMP continues to offer buyer support tools, such as efficiency 
3-17

guidelines, cost-effectiveness examples, and a cost calculator. FEMP also offers training, on-site 

audits, demonstrations, and design assistance.6

3.3.4.2 Consortium for Energy Efficiency 

 The Consortium for Energy Efficiency (CEE) has both a Residential Lighting Initiative 

and a High Performance Commercial Lighting Initiative. The Residential Lighting Initiative 

primarily promotes high efficiency fixtures and CFLs, neither of which are covered under this 

rulemaking. The purpose of CEE’s High Performance Commercial Lighting Initiative is to 

define what constitutes “high performance,” and the initial efforts have focused on efficient T8 

fluorescent lighting products. On May 1, 2007, CEE updated its specification for high 

performance T8 lamps as a T8 lamp not greater than 32W, with minimum initial lamp lumens of 

3,100 lumens or greater.7 On January 23, 2007, CEE released its specification for reducedwattage T8 lamps as a lamp of 28W or 25W with minimum initial lumen output greater than or 

equal to 2,585 lumens or 2,400 lumens, respectively. CEE also provides a database of detailed 

information on over 160 utilities and efficiency program administrators that offer prescriptive 

incentives towards the purchase of high efficiency commercial lighting equipment. The 

information was compiled in April 2011 and includes information on measures specifically 

involving fluorescent lamps and ballasts, fluorescent fixtures, other lighting technologies, and 

lighting controls.8

3.3.4.3 Energy Efficient Commercial Building Deduction 

The Energy Policy Act of 2005 (Pub. L. 109-58; 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. Originally effective for 

property in service from January 1, 2006 through December 31, 2008, the measure allows partial 

deductions for improvement in interior lighting. Projects must be certified to reduce total annual 

energy and power costs solely through changes to the building’s lighting, HVAC/hot water, and 

building envelope to at least 50 percent less than a reference building satisfying the requirements 

of ASHRAE/IESNA 90.1-2001, or to at least 10-20 percent less energy consumption through 

lighting alone. Though the statute does not specify required lamp types or efficacies, it does call 

for an overall reduction in lighting power density. 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. 

3.3.4.4 Efficiency Vermont – Agricultural Rebate Program 

In Vermont, agricultural operations are eligible for prescriptive and customized 

incentives on equipment proven to help make farms more efficient. Efficiency Vermont gives 

prescriptive rebates for a variety of equipment and for lighting. Efficiency Vermont will rebate 

$50 to $100 per T12 fluorescent system replaced with a high performance T8 fluorescent system, 

or a T5 HO fluorescent system. This version of the rebate expires at the end of 2013.9

3.3.4.5 Pacific Gas and Electric Company Rebates

Through the Rebates for Multi-Family Properties Program, Pacific Gas and Electric 

Company (PG&E) offers prescriptive rebates for owners and managers of multi-family 

California properties of two or more units. Fluorescent lighting improvements are among the 
3-18

eligible products for rebates. All equipment must meet program requirements listed on the PG&E 

program web site or application forms. Owners or managers can receive rebates of $25 to $45 

per T8 or T5 fluorescent lamp-and-ballast system.10 PG&E also offers rebates and other 

incentives to businesses and non-residential customers to increase their energy efficiency. To this 

effect, PG&E offers incentives for efficient building design and other energy efficient 

improvements, including high performance GSFLs. PG&E will give rebates of $4.50 to $9 per 

T5 or T8 lamp installed, $1 to $1.50 per full wattage T8 lamp replaced with a lower wattage 

lamp, and $6 to $20 per T12 lamp removed from a fixture (i.e., delamping).11 These rebates 

expire March 1, 2013. 

3.3.4.6 Northeast Energy Efficiency Partnerships 

Northeast Energy Efficiency Partnerships (NEEP) is a regional nonprofit organization 

that promotes energy efficiency in the Northeast United States. NEEP currently runs both a 

Commercial Lighting Technologies initiative and a High Efficiency Residential Lighting 

initiative. Through these programs, NEEP coordinates with and sponsors multiple local and state 

governments, utilities, and other initiatives, such as Efficiency Vermont and the Long Island 

Power Authority, to promote efficient lighting products. NEEP’s involvement in the commercial 

sector is focused on whole building energy use and using efficacious lamps, including certain 

fluorescent lamps, to meet various lower energy use goals, moving toward net zero energy 

buildings.12 NEEP’s residential lighting work aims to accelerate market adoption of high 

efficiency residential lighting by encouraging its members to implement their regional 

Residential Lighting Strategy (RLS), which includes the support of halogen IRLs, along with 

other efficacious technologies.13

3.3.4.7 APS Rebate Programs 

 In Arizona, APS offers a number of incentives and rebate programs. Solutions for 

Business offers incentives that help businesses increase energy efficiency and reduce energy use. 

APS non-residential customers (including schools, small businesses, industrial facilities and 

public agencies) can choose energy efficiency measures with rebates for existing buildings and 

new construction. For this program, APS provides a rebate for T8 and T5 fluorescent lamps and 

electronic ballasts at $5 to $12 per lamp-and-ballast system. APS also offers energy efficiency 

incentives to multi-family building residents. The program provides incentives for new 

construction and major renovation multi-family projects. Through this program, APS offers a 

rebate of $5 to $10 per T8 and T5 fluorescent lamp.These programs expire at the end of 2012, 

but they are expected to be renewed pending Commission approval.14,15

3.3.4.8 Cape Light Compact – Commercial, Industrial and Municipal Buildings 

Energy Efficiency Rebate Program 

Through a multi-member partnership, Cape Light Compact (CLC) and Masssave offer a 

variety of financial incentives for commercial, industrial, and municipal facilities in 

Massachusetts. Custom rebate options are available for both new construction and retrofit 

measures in commercial/industrial buildings, as well as for small businesses and municipal 

projects. There are prescriptive rebates through the partnership on sensors and fluorescent 

lighting equipment and controls for eligible new and existing buildings. Rebates vary depending 

on whether projects are retrofit or new construction. Through this program, CLC offers $10 to 

$50 per fluorescent fixture in retrofits, and $10 to $35 per high efficiency fluorescent system 
3-19

along with $0.40 to $1.00 per watt saved through lighting in new construction. This program 

expires October 31, 2015.16

3.3.4.9 Central Electric Cooperative – Non-Residential Lighting Rebate 

In Oregon, the Central Electric Cooperative offers a commercial lighting system 

improvement incentive for any customer not on a residential utility rate. The Central Electric 

Cooperative will give rebates of $10 to $40 per T12 fluorescent lamp-and-ballast replaced with a 

T5 or T8 fluorescent lamp-and-ballast, $120 to $180 per high bay fixture of other lighting 

technology (e.g., mercury vapor, high pressure sodium, metal halide, incandescent) replaced with 

a T8 or T5 fluorescent high bay fixture, and $50 to $100 per T12 fluorescent lamp fixture 

replaced with a T5 fluorescent lamp fixture. This rebate will continue through October 1, 2013 

and is expected to be extended past that date. The Central Electric Cooperative will give a sixmonth notice of alterations to the program.17

3.3.4.10 Empire – Commercial and Industrial Energy Efficiency Rebates 

The Empire District Electric Company (Empire) offers a Commercial/Industrial 

Prescriptive Rebate Program to its non-residential customers in Arkansas who purchase certain 

high efficiency equipment for eligible facilities. A variety of prescriptive rebates are available to 

customers served under any non-residential rate schedule in the Empire service territory. The 

rebates, which can be applied to both new construction and retrofit projects, are offered for 

certain equipment meeting the program’s energy efficiency standards. Empire offers a rebate of 

$0.50 to $16 per fluorescent lamp-and-ballast system, $9 to $18 per high performance T8 

fluorescent lamp system, $40 to $125 per high bay fluorescent lamp-and-ballast system, $16 to 

$24 per pendant, wall mount, or recessed indirect fixture, and $50 per high intensity fluorescent 

lamp fixture. There are no expiration dates for these rebates at this time.18

3.3.4.11 GVEA – Residential Rebate Program for Builders 

Alaska’s Golden Valley Electric Association’s (GVEA) Builder $ense program targets 

home builders who install electrical energy efficiency measures during construction of 

residential buildings. Newly constructed residential buildings or residential buildings that have 

had major remodeling or additions are eligible for the rebate. The program gives a $20 rebate for 

all linear fluorescent lamps, except for T12s. In most cases, the applicant must have a minimum 

of four hard-wired fluorescent fixtures to be eligible. There is no expiration date for this program 

at this time.19

3.3.5 Historical Shipments 

 Shipment data and market trend information are used to conduct the shipment analysis 

and develop base-case forecasts in the shipment analysis (see chapter 9 of this TSD). DOE also 

uses shipment data to identify and analyze representative product classes and lamps to ensure the 

analysis is representative of the market (see chapter 5 of this TSD). Shipment data also feeds into 

the national impact analysis (see chapter 10 of this TSD). Based on its understanding of trends in 

the market, DOE estimated how the market would respond to the various CSLs. The following 

section outlines the publicly available historical data and trends for GSFLs and IRLs. For the 

2009 Lamps Rule, NEMA provided historical shipments of GSFLs and IRLs from 2001 to 2005 
3-20

in a public comment,20 and for this rulemaking, NEMA provided GSFL and IRL historical 

shipments for 2006 through 2011 to DOE upon request. 

3.3.5.1 GSFL Shipments 

For GSFLs, the historical shipment data is broken down by lamp length (2-foot, 4-foot, 

and 8-foot), diameter (T12, T8, and T5), shape (linear and U-shaped), and in some cases, lumen 

output (SO or HO). Four-foot MBP lamps have consistently constituted the vast majority of 

GSFL sales. These have been followed, in order of unit sales, by 8-foot SP slimline lamps, then 

8-foot RDC HO lamps, with shipments of 2-foot U-shaped lamps consistently making up the 

smallest portion (less than five percent) of unit sales. After 2005, 8-foot RDC HO lamp 

shipments declined to less than five percent as well, nearly equaling 2-foot U-shaped lamp 

shipments. For this rulemaking, NEMA provided DOE with combined shipment data for 4-foot 

T5 MiniBP SO and HO lamps from 2006 through 2011, showing an increasing share of unit 

sales that reached a little over eight percent of shipments in 2011. 

 GSFLs in the categories of 4-foot MBP, 8-foot SP slimline, 8-foot RDC HO, 2-foot Ushaped, and T5 SO and HO lamps are primarily used in the commercial and industrial sectors. As 

Table 3.3.11 shows, 4-foot MBP fluorescent lamp shipments show a clear decrease in the T12 

market share and an increase in the T8 market share. These shipments, coupled with information 

obtained from NEMA and feedback from interviews with manufacturers, suggest that consumers 

are moving away from 4-foot T12 fluorescent lamps and toward 4-foot T8 fluorescent lamps. 

This trend is reflected both in the popularity of T8 lamps in new construction and in lighting 

system retrofits and renovations where the ballast is replaced. The vast majority of ballasts are 

electronic, with instant start (IS) technology composing about 85 to 90 percent of the market. 

The decline of 4-foot T12 shipments was compounded by energy conservation standards for T12 

fluorescent ballasts, requiring compliance in 2009 and 2010. (See 10 CFR 430.32(m)(4)(ii) and 

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

Table 3.3.11 NEMA Shipments of Four-Foot Medium Bipin GSFLs 

T12 4-Foot MBP T8 4-Foot MBP Total 4-Foot MBP

Unit Sales by Year

thousands

2001 212,564 164,129 376,593

2002 205,998 163,632 369,630

2003 181,931 172,294 354,225

2004 175,850 195,698 371,548

2005 162,664 215,530 378,194

2006 150,522 230,988 381,510

2007 131,584 247,331 378,915

2008 115,064 253,705 368,769

2009 111,500 219,101 330,601

2010 103,300 233,798 337,098

2011 92,588 265,889 358,477

As Table 3.3.12 shows, historical shipments of 8-foot SP slimline GSFLs reflect a decline 

in shipments of T12 lamps through 2009, but not an increased market share in T8 lamps that 

compensates for this decrease. There was a brief increase in shipments of 8-foot SP slimline 
3-21

lamps in 2010, however, shipments began to show a decrease again in 2011. Manufacturer 

feedback indicated that a portion of the 8-foot T12 market is being transferred to the 4-foot T8 

market as two 8-foot T12 lamps can be replaced by four 4-foot T8 lamps. 

Table 3.3.12 NEMA Shipments of Eight-Foot Single Pin Slimline GSFLs 

T12 8-Foot SP Slimline T8 8-Foot SP Slimline Total 8-Foot SP Slimline

Unit Sales by Year

thousands

2001 43,265 4,405 47,670

2002 41,443 5,300 46,743

2003 37,170 5,183 42,353

2004 36,263 5,727 41,990

2005 33,636 5,176 38,812

2006 27,030 5,721 32,751

2007 25,400 4,718 30,118

2008 22,208 4,480 26,688

2009 20,944 4,902 25,846

2010 30,396 5,112 35,508

2011 26,210 4,306 30,516

Table 3.3.13 shows the historical shipments of 2-foot U-shaped GSFLs. While U-shaped 

T12 lamp shipments are declining, no clear trend can be seen in the market share progression of 

U-shaped T8 lamps. Nonetheless, the market share of U-shaped lamps has remained small 

compared to that of 4-foot MBP and 8-foot SP slimline lamps. 

Table 3.3.13 NEMA Shipments of Two-Foot U-Shaped GSFLs 

T12 2-Foot U-Shaped T8 2-Foot U-Shaped Total 2-Foot U-Shaped

Unit Sales by Year

thousands

2001 9,672 8,014 17,686

2002 9,314 6,784 16,098

2003 9,460 7,018 16,478

2004 7,014 9,224 16,238

2005 8,839 8,659 17,496

2006 5,803 12,086 17,889

2007 5,169 11,502 16,671

2008 4,626 9,382 14,008

2009 3,882 8,455 12,337

2010 3,683 8,786 12,469

2011 3,574 9,012 12,586

While 4-foot MBP, 8-foot SP slimline, and 2-foot U-shaped lamps are primarily used in 

the commercial sector, 8-foot RDC HO lamps are primarily used in the industrial sector for 

applications such as high bay lighting. Table 3.3.14 shows the historical shipments of 8-foot 

RDC HO lamps. The market share of 8-foot RDC HO is relatively small compared to that of 4-

foot MBP and 8-foot SP slimline lamps. As seen in NEMA’s historical shipment data, T12 8-

foot RDC HO lamps had the majority of the RDC HO market. After 2005, NEMA reported T12 
3-22

and T8 8-foot RDC HO data as combined totals for disclosure purposes. Discussions with 

manufacturers indicate that they expect any migration of the 8-foot RDC HO market to go 

toward T5 HO lamps. 

Table 3.3.14 NEMA Shipments of Eight-Foot Recessed Double Contact High Output 

GSFLs 

T12 8-Foot RDC HO T8 8-Foot RDC HO Total 8-Foot RDC HO

Unit Sales by Year

thousands

2001 23,887 691 24,578

2002 24,398 647 25,045

2003 24,206 467 24,673

2004 24,591 674 25,265

2005 25,442 420 25,862

2006 -- -- 18,828

2007 -- -- 19,741

2008 -- -- 18,575

2009 -- -- 15,799

2010 -- -- 15,408

2011 -- -- 15,286

 

Table 3.3.15 shows NEMA’s 2006 through 2011 combined HO and SO 4-foot T5 

MiniBP lamp shipments. While 4-foot MBP lamps have always held the definitive majority of 

the market, 4-foot T5 MiniBP lamps are gaining an increasing market share and have become the 

next most prevalent lamp type, surpassing 8-foot SP slimline lamps in 2011. Still less than 10 

percent of the market, 4-foot T5 MiniBP shipments (according to manufacturer interviews, 

specifically T5 HO shipments) have grown due to commercial applications using the higher 

efficacy lamps and industrial high bay applications switching from less-controllable technologies 

(e.g., high-intenisty discharge [HID] lamps). Additionally, the increase of 4-foot T5 MiniBP 

shipments has also been influenced by non-regulatory incentives such as utility rebates. Several 

programs offer rebates to commercial, non-residential, and multi-family customers for the 

installation of T5 lamps in both new construction and renovation applications (see section 3.3.4

for examples). As mentioned previously, 4-foot T5 MiniBP HOs are also expected to capture a 

portion of the 8-foot RDC HO market. 

Table 3.3.15 NEMA Shipments of Four-Foot T5 Miniature Bipin Standard Output and 

High Output GSFLs 

Total 4-Foot T5 

MiniBP SO and HO

Unit Sales by Year

thousands

2006 21,465

2007 26,318

2008 28,784

2009 24,815

2010 32,508

2011 37,930
3-23

3.3.5.2 IRL Shipments 

 As Table 3.3.16 shows, both halogen and non-halogen IRL shipments have been 

declining since 2006. However, the halogen reflector lamp types are generally maintaining their 

percentage of total shipments. 

Table 3.3.16 NEMA Shipments of IRLs 

PAR 

Incandescent R Incandescent PAR 38 Halogen PAR 30 and PAR 20 Halogen Total IRLs

Unit Sales by Year

thousands

2001 8,900 89,465 40,804 32,523 171,692

2002 6,697 96,218 45,938 27,128 175,961

2003 5,090 103,407 45,673 30,506 184,676

2004 5,308 111,720 49,937 35,567 202,532

2005 15,018 124,641 46,329 39,985 225,973

2006 4,800 121,308 43,265 36,054 205,427

2007 3,658 114,521 40,377 36,390 194,946

2008 3,228 99,446 36,209 34,320 173,203

2009 2,237 89,288 39,039 30,483 161,047

2010 2,778 86,681 36,106 30,872 156,437

2011 2,100 85,293 35,372 27,815 150,580

3.4 TECHNOLOGY ASSESSMENT 

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

that could be used to improve the efficacy of GSFLs and IRLs. The following assessment 

provides a description of the basic construction and operation of GSFLs and IRLs, followed by 

technology options to improve efficacy. 

3.4.1 Basic Structure and Operation of General Service Fluorescent Lamps 

The fluorescent lamp is a low pressure gas discharge source. The 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. Once voltage is applied, the electrodes emit large quantities of electrons 

that then collide with gaseous mercury atoms, exciting electrons within those atoms. As the 

electrons decay to their stable or ground state, they emit ultraviolet (UV) radiation. The 

phosphors coating the bulb’s inner wall then absorb this UV radiation and emit light in the 

visible spectrum. The fluorescent lamp has five major components in its construction: 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), lamp designs 

may use different bases such as SP, MBP, MiniBP, 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 
3-24

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. As discussed 

above, the UV radiation is then absorbed by the phosphors and reemitted as light. 

 A fluorescent lamp must be operated in series with a current-limiting device, which is 

usually a magnetic or electronic ballast. The 2011 Ballast Rule set standards difficult for 

magnetic ballasts to meet (76 FR 70548 [Nov. 14, 2011]); while electronic ballasts, the more 

efficient technology, will be able to meet standards. While this rulemaking covers only the 

fluorescent lamp, it does evaluate the lamp-and-ballast system when evaluating energy savings 

of a particular GSFL efficacy level. 

 In addition to limiting current, ballasts also supply starting and operating voltages 

required by the lamp. Some ballasts also preheat the electrodes before initiating the arc. 

Electronic ballasts can use a variety of starting methods, including IS, rapid start (RS), and 

programmed start (PS).j RS ballasts heat the electrodes for a limited time before lamp ignition 

which leads to a longer lamp life than an IS ballast. However, RS ballasts have difficulty 

complying with standards set in the 2011 Ballast Rule. 76 FR 70548 (Nov. 14, 2011). PS

ballasts, like RS, heat the lamp filaments before igniting the lamp and some remove all power to 

the electrodes after ignition (i.e. cathode cut-out) resulting in more energy savings compared to 

RS ballasts. IS ballasts apply a higher voltage to initiate the lamp ignition rather than applying a 

steady filament voltage. 

 Because different starting methods result in changes in lamp efficacy, the test procedure 

for GSFLs requires that the efficacy of each lamp is measured using a common starting method 

and ballast. However, DOE considers different starting methods in its analysis. For example, 

DOE pairs 4-foot T8 MBP lamps with electronic, IS ballasts and electronic, PS ballasts. 

Electronic ballasts are also available in a variety of lamp-per-ballast designs. For example, 

electronic ballasts are typically manufactured in 1-, 2-, 3-, 4- and 6-lamp versions. In its analysis 

for this rulemaking, DOE is focusing on the more prevalent 2- and 4-lamp systems. 

Some of the performance parameters used to characterize a ballast include ballast factor 

(BF), ballast luminous efficiency (BLE), and power factor. Each ballast has a BF, which is the 

output of the 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 BF. BLE, a new metric for 

fluorescent lamp ballasts, means the total lamp arc power divided by the ballast input power 

multiplied by the appropriate frequency adjustment factor. BLE describes the percentage of 

ballast input power that is used by the lamp to produce light. The power factor is calculated by 

determining the ratio of the active power to the apparent power. 

 

j

 Programmed start ballasts delay the starting voltage until the electrodes are heated to an optimum temperature. 

Then, they may reduce the voltage on the electrodes. 
3-25

Fluorescent lamp bulbs can be manufactured in a variety of shapes and sizes. The GSFLs 

in this rulemaking include 4-foot and 8-foot linear lamps and 2-foot U-shaped lamps. Changing 

the shape of the lamp can alter the overall efficacy as the lamp may require a different voltage to 

maintain the discharge and UV radiation. In addition, the length of a lamp also influences its 

efficacy. As Figure 3.4.1 shows, the greater the length, the higher the efficacy, since losses 

associated with the electrodes are essentially constant. Therefore, a longer arc length will have 

less electrode power losses relative to the total losses. However, because different lamp shapes 

and lengths may provide different utility to the consumer and also depend on the fixture, DOE is 

not considering these properties as technology options. Rather, as indicated in the discussion of 

product classes in section 3.5.1, product classes differentiate lamps by their shape and length. In 

its analysis, DOE was unable to determine if base type alone impacted efficacy and therefore did 

not consider this as a technology option. 

Figure 3.4.1 Lamp Length Effects on Efficacy 

Source: IESNA Lighting Handbook: Reference & Application21

3.4.2 GSFL Technology Options 

 This section outines the technology options DOE is considering for improving efficacy of 

GSFLs. In discussing each of the following technology options, it is important to note that the 

efficacy of a lamp, in terms of lumens per watt (lm/W), can be affected in two major ways. One 

method is by affecting the total light output at a given wattage. This generally refers to changing 

the spectral output of the lamp to result in a larger overlap with the spectral eye sensitivity.k

The 

second method of changing lamp efficacy is requiring a different electrical wattage input to 

maintain a given lumen output. This method involves tweaking the processes that convert 

electrical energy to visible radiation. 

 

k

 A “lumen” is a measurement of the radiometric energy emission from a light source weighted by the response 

function of a human eye, called the photopic spectral luminous efficiency function, V(λ). See Figure 3.4.4 for a 

graph of this function. 
3-26

3.4.2.1 Highly Emissive Electrode Coatings 

Fluorescent lamp electrodes are generally tungsten filaments coated with a mixture of 

alkaline earth oxides. The purpose of the electrodes is to emit a sufficient number of electrons to 

ionize the gas and maintain the lamp discharge. When electrons are more easily emitted from the 

electrodes, a lower voltage is needed to maintain the arc. Therefore, any improvement in 

electrode coating that would allow electrons to be more easily removed from the electrodes 

would reduce the lamp power and increase the overall efficacy of the lamp. This technology 

option essentially addresses the efficiency of the conversion of electrical input power to visible 

radiation. In addition to raising efficacy, the electrode coatings can result in an increased lamp 

lifetime. Without sufficient electron emission from the electrode, a large voltage gradient is 

created in front of the electrode during the cathode cycle, which is emitting negatively charged 

ions and receiving positively charged ions. This high electric field accelerates these ions into the 

electrode at a high velocity, causing electrode damage. The damage shortens the lifetime of the 

lamp. Conventional emissive coatings include barium oxide (BaO), calcium oxide (CaO), and 

strontium oxide (SrO). Additional materials have been mixed with existing conventional oxides 

to coat fluorescent lamp electrodes. These materials include zirconium oxide (ZrO), which 

extends lamp lifetime, and silicon carbide (SiC), which more effectively removes electrons from 

the electrode. 

3.4.2.2 Higher Efficiency Lamp Fill Gas Composition 

Fluorescent lamps contain mercury vapor, which when ionized produces UV radiation. 

They also contain a rare gas or combination of gases to facilitate ignition. These “lamp fill 

gases” affect the mobility of the mercury ions and electrons in the lamp plasma based on their 

molecular weight. Lower molecular weight gases generally result in higher lamp efficacy. As 

lighter gases are used, the mobility of mercury ions and electrons increases, allowing them to 

reach greater velocities. This causes a rise in electron temperature of the plasma, facilitating 

recombination and ultimately raising the UV radiation to saturation level. However, if the 

mobility of the ions and electrons exceeds a certain optimal point, they are then able to reach the 

lamp glass surface, which prevents emission and effectively reduces UV output. 

Standard lamps generally use argon gas. Energy-saver lamps may use a mixture of 

krypton and argon. In addition, neon and xenon are sometimes blended with argon. As Figure 

3.4.2 shows, given a linear power density of 25 watts/foot (W/ft), both neon and argon result in 

similar UV radiation. However, given a high linear power density of 50 W/ft, neon clearly allows 

for higher UV radiation, and therefore higher efficacy. 
3-27

Figure 3.4.2 Lamp Fill Gas Effect on UV Output for T12 Lamps 

Source: Electric Discharge Lamps 22

These gases are usually at low pressures, ranging from 100 to 400 Pascals. As the 

pressure exceeds a certain point, elastic scattering increases, decreasing the mobility of the ions 

and electrons. This decreased mobility lowers the total UV radiation of the lamp, thereby 

decreasing lamp efficacy. Because fluorescent lamp ballasts are often current-controlled devices, 

the use of higher efficiency lamp fill gases, such as krypton, results in lower power. DOE 

research and interviews with manufacturers have indicated that these lower power lamps, often 

called energy-saver lamps, have some restrictions on usage, such as operation in less than 65 °F 

ambient temperature, with some dimming ballasts, etc. 

Lamp fill gas composition can also affect lamp lifetime due to collisions between the 

lamp fill gas and the evaporated electrode coatings. As discussed earlier, one common emissive 

coating used on electrodes is barium oxide (BaO). During lamp operation the BaO coating 

slowly evaporates from the surface of the electrode. However, some of these escaped barium 

atoms then collide with the lamp fill gas, propelling them back toward the electrode and 

redepositing them. As Figure 3.4.3 shows, the relative thermionic emission for the cathode, a 

measure of the number of electrons emitted, is much greater for a larger molecular weight gas, 

such as krypton, than for a lighter gas, such as neon. This is because a larger mass atom can more 

effectively collide with and change the trajectory of the barium atoms, providing a lower 

diffusion rate of the barium atoms away from the electrode. This redeposition of the electrode 

coating results in a longer lamp lifetime as less of the electron emissive material is lost. 
3-28

Figure 3.4.3 Lamp Fill Gas Effect on Thermionic Emission for T12 Lamps 

Source: Electric Discharge Lamps 23

3.4.2.3 Higher Efficiency Phosphors 

As described earlier, the main purpose of phosphor in a fluorescent lamp is to absorb the 

UV radiation and reemit it as visible radiation. Therefore, one method of improving lamp 

efficacy is to increase phosphor efficiency. The two groupings of phosphors used in fluorescent 

lamps are halophosphors and triband phosphors, the latter of which contain rare earth elements. 

Initially, halophosphors, typically composed of group 17 elements from the periodic table of 

elements, were predominantly used in fluorescent lamps. Then, in the late 1980s, rare earth 

phosphors, which are generally considered to have higher phosphor efficiencies, better color 

rendering properties, and improved lumen maintenance, were integrated into the lamps. 

Specifically, these narrow-band rare earth phosphors (containing the rare earth elements terbium, 

europium, and yttrium), emit light in the short, middle, and long wavelength ranges of the visible 

spectrum. Lamps that meet the July 2012 standards predominately use triband phosphors, which 

include rare earth phosphors.24 However, the more efficient fluorescent lamps on the market 

today exclusively use triband phosphors.

Therefore, lamp efficacy can be improved by using triband phosphors, which can 

increase UV absorption and emission of radiation in the visible spectrum relative to other 

phosphors. Typically, there are efficiency losses in the phosphor’s conversion of UV radiation to 

visible radiation, or light. Some of these losses are related to the extent to which the phosphors 

emit light in the visible spectrum (i.e., radiation with wavelengths between 400 to 750 nm) and 

the extent that they radiate at visually sensitive wavelengths. Triband phosphors allow a lamp to 

emit light at the wavelengths to which human eyes are most sensitive which increases lamp 

efficacy. To understand this effect it is important to note the relationship between the efficiency 

losses in the phosphor’s conversion of light, wavelengths sensitive to the human eye, and 

measurement of lamp efficacy.

Lumens, used to calculate lamp efficacy, measure the radiometric energy emission from a 

light source weighted by the response function of the human eye, V(λ) (also referred to as the 
3-29

photopic luminous efficiency function). Figure 3.4.4 depicts V(λ). The human eye does not have 

the same level of sensitivity to all wavelengths of light. For example, the eye is highly sensitive 

to light emission around 550 nm, but less sensitive to emission at 450 nm or 650 nm. 

Figure 3.4.4 Human Eye Photopic Spectral Luminous Efficiency Function, V(λ) 

Therefore, the specific wavelengths that a lamp emits will affect the lamp’s calculated 

efficacy. In other words, because the human eye is less responsive to certain wavelengths of 

light, such as those in the blue spectrum, those lamps that contain these less sensitive 

wavelengths will have lower efficacies. As such, every watt of radiometric energy emitted from a 

fluorescent lamp is not equal under a lm/W metric. Therefore, by allowing a lamp to emit greater 

light at wavelengths to which the human eye is more sensitive, triband phosphors are able to 

increase lamp efficacy. 

Lamp efficacy can also be improved by increasing the thickness of the phosphor layer, 

also called phosphor weight. Generally, as phosphor thickness increases, lamp light output 

increases until it slightly decreases or stays flat. Figure 3.4.5 illustrates this point, where coating 

weight is indicative of phosphor thickness. 

-

0.2

0.4

0.6

0.8

1.0

1.2

400 450 500 550 600 650 700 750

Wavelength (nanometers)

Relative Sensitivity
3-30

Figure 3.4.5 Light Output versus Phosphor Thickness 

Source: Journal of the Electrochemical Society 25

Different types of phosphor emit light with different spectral power distributions (SPDs), 

and the choice of phosphor or blend of phosphors greatly affects the color of the lamp. The SPD

of light emitted from a lamp characterizes the amount of power radiated at each wavelength in 

the visible spectrum. Figure 3.4.6 illustrates a sample SPD. It is apparent that the light source 

emits more radiation at certain wavelengths than others. 

Figure 3.4.6 Sample Power Spectrum Distribution 

Source: www.gelighting.com26

This SPD determines the correlated color temperature (CCT) and the CRI, both important 

properties for measuring the color quality of light. CRI, a single value with no units, is a measure 

of the color rendering properties of a light source, or the ability of a light source to show the 
3-31

“true” color of an object as compared to a reference source.l 27 The maximum CRI is 100. Lower 

CRI values indicate greater variation in an object’s apparent color compared to when lit by the 

reference source. DOE has observed that higher efficiency phosphors on the market typically 

offer higher CRIs. While CRI is not necessarily positively correlated to efficacy, the majority of 

phosphors offered in the market currently reflect this relationship. Typically lamps with a CRI in 

the 60s use only less efficient halophosphors, while lamps with a CRI in the 70s (700-series 

phosphor) and in the 80s (800-series phosphor) use more efficient rare earth phosphors. 

Currently, the majority of lamps compliant with the July 2012 standards are 800 series. 

CCT, a single value with units of degrees Kelvin (K), is a measure of the color 

appearance of light emitted from a lamp.m n 28 Lower CCT values correspond to warmer light, 

with more red content in the spectrum, and higher CCTs correspond to cooler light, with more 

blue content. As the spectral emission from the lamp is modified to change the CCT, the light 

emitted often contains more red or blue light. Given the shift in the wavelengths of light emitted 

from lamps with different CCTs, and the fact that lumens account for the amount of light emitted 

at particular wavelengths, the efficacy of lamps with different CCTs can vary. 

3.4.2.4 Glass Coatings 

To increase the UV absorption by the phosphors, the bulb glass can be covered with an 

antireflective coating. This coating, also referred to as the undercoat or base coat layer, is a 

refractory oxide, such as aluminum oxide (Al2O3), silicon oxide (SiO2), and titanium oxide 

(TiO2). This layer is used to reflect any UV radiation that passes through the phosphor back onto 

the phosphor, allowing a greater portion of UV to be absorbed. As the phosphors absorb more 

UV radiation, they will emit more visible light, thereby increasing the overall efficacy of the 

lamp. When these coatings are used with rare earth phosphors, a good CRI can be achieved while 

minimizing the phosphor thickness necessary to absorb maximum UV radiation. A recent 

patent29 by Philips was issued in 2005 for an improved undercoat that reduces the amount of 

lamp contaminant resulting from the manufacture process. The improved coating covered under 

the patent contains an aluminum oxide material and a getter material which reacts with 

contaminants. This reduction or elimination of contaminants results in improved lamp arc 

stability. 

3.4.2.5 Higher Efficiency Lamp Diameter 

Similar to lamp length, lamp diameter is another design parameter of a fluorescent lamp 

that can affect efficacy. As Figure 3.4.7 shows, there exists an optimum design diameter for a 

specific fluorescent lamp type resulting from two opposing effects. First, in small diameter 

 

l

 According to the IESNA Lighting Handbook, the CRI of a light source is “a measure of the degree of color shift 

objects undergo when illuminated by the light source as compared with those same objects when illuminated by a 

reference source of comparable color temperature.” 

m

 According to the IESNA Lighting Handbook, the CCT of a light source is “the absolute temperature of a 

blackbody whose chromaticity most nearly resembles that of the light source.” 

n

 While CCT is a single value, light with the same CCT value may have slightly different properties. Therefore, the 

lighting industry has defined elliptical regions in chromaticity space (called 4 MacAdam color steps) for specific 

CCT values (e.g., 2,700K, 3,000K, 3,500K, 4,000K/4,100K, 5,000K, and 6,500K) in ANSI C78.376-2001. These 

regions act as a tolerance for the color properties of the lamp. 
3-32

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 efficacy-diameter 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 

addition to affecting lamp efficacy, changing the lamp diameter alters the inner surface area of 

the fluorescent tube. With a larger diameter and therefore surface area, more phosphor is needed 

to coat the glass, subsequently increasing the cost of the lamp. 

Figure 3.4.7 Bulb Diameter versus Efficacy 

Source: IESNA Lighting Handbook: Reference & Application30

DOE only considered lamp diameter as a design option in relation to the migration from 

T12 to T8 lamps. DOE’s research indicated T8 lamps are common replacements for T12 lamps, 

and though the lumen packages for T8 lamps are often less than that of T12 lamps, in this 

situation, it does not seem to be significant enough to affect consumer utility. Conversely, DOE’s 

research indicated that T5 lamps have more limited utility as replacements for T8 or T12 lamps 

due to the fewer available lumen packages for T5 lamp-and-ballast sytems. As such, T5 lamps 

are not considered a design option to improving the efficacy of T8 and T12 lamps. See section 

3.5.1.3 for more information. 

3.4.2.6 Multi-Photon Phosphors 

The use of multi-photon phosphors, or quantum-splitting phosphors, can significantly 

improve lamp efficacy. Because these phosphors emit more than one visible photon for each 

incident UV photon, a lamp would be able to emit more light in the visible spectrum for the same 

amount of power. However, there are technical drawbacks with the technology such as light 

color output, color stability, and phosphor lifetime.31
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3.4.3 Basic Structure and Operation of Incandescent Reflector Lamps 

An incandescent lamp is a light source in which an electrical current passes through a 

filament, thermally exciting electrons, which then radiate energy in the form of light and heat. 

Incandescent lamps consist of a bulb, generally composed of glass such as regular lead, soda 

lime, or borosilicate heat-resisting glass. Within the bulb, an incandescent lamp contains a 

filament, filament supports, and sometimes a lamp fill gas. Though early incandescent lamps 

often used carbon, osmium, and tantalum filaments, current lamps generally use tungsten 

filaments. Tungsten’s low vapor pressure and high melting point allows for high operating 

temperatures, and consequently high lamp efficacies. The lamp fill gas, though not included in 

all incandescent lamps, is used to extend the lifetime of the lamp. 

IRLs are incandescent lamps with a reflective coating, most commonly composed of 

aluminum or silver applied directly to the reflector surface. Sealed to the bulb of the IRLs 

covered in this rulemaking is an E26 medium screw base. By improving directional lighting, 

reflector lamps place the same illuminance on a specific area with reduced watts. The most 

common bulb shapes of reflector lamps are R, PAR, BR, and ER. R-, ER- and BR-shaped lamps 

are primarily for indoor applications, while PAR lamps are usually used outdoors or for 

spotlighting in retail applications. IRLs can have spot or flood beams. Flood IRLs, which provide 

a greater distribution of light, typically have a beam spread of 16 to 40 degrees. Spot IRLs 

usually have a beam spread from 9 to 16 degrees. The ranges change with lamp type, with PAR 

lamps typically having smaller beam spreads than other IRLs. 

Most IRLs on the market today are tungsten-halogen lamps. Tungsten-halogen lamps use 

a halogen element such as bromine, chlorine, fluorine, or iodine to help increase lifetime of the 

lamp. In a tungsten-halogen lamp, a small diameter fused quartz envelope, commonly known as 

a capsule or burner, filled with a halogen molecule surrounds the filament. Above 500 degrees 

Fahrenheit (F), when tungsten evaporates from the filament, the tungsten molecules combine 

with the halogen into a gaseous compound. This compound circulates within the envelope until it 

contacts the filament again. The heat of the filament breaks the compound, freeing the halogen 

and redepositing the tungsten on the filament. This regenerative process greatly extends the life 

of incandescent lamps by reducing the loss of tungsten material. Further, because tungsten is not 

being deposited on the surface, lamp blackening is greatly reduced. However, there is a 

minimum temperature threshold for the halogen cycle to continue, so if dimmed tungstenhalogen lamps, which employ low-voltage operation, become blackened, they should 

periodically be operated at full power in order to induce the halogen cycle that will remove the 

tungsten off the capsule wall. One drawback to using halogen is that the halogen capsule is often 

under high pressure and therefore susceptible to non-passive failure. For this reason, halogen 

IRLs often employ a thicker protective glass. 

3.4.4 IRL Technology Options 

The following assessment is a discussion of technology options that improve the efficacy 

of IRLs. In discussing methods to affect the efficacy of an incandescent lamp, it is important to 

recognize the interrelation of a lamp’s wattage, luminous output, and lifetime. Often the most 

efficacious incandescent lamps have very low lifetimes and therefore become useless to the 

consumer. However, it is possible to optimize both efficacy and lifetime so that the lamp still 

provides utility to the consumer. 
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3.4.4.1 Higher Temperature Operation 

In the operation of an incandescent lamp, a current is passed through a tungsten filament, 

which when heated, emits light. However, an incandescent light source’s spectrum does not fall 

exclusively in the visible region of the electromagnetic spectrum. This overlap is shown by 

Curve B, representing the radiant flux from one square centimeter of tungsten at 3,000 K, in 

Figure 3.4.8.

o By operating the filament at higher temperatures, the spectral output shifts to 

shorter wavelengths, increasing its overlap with the photopic spectral eye sensitivity. This, in 

effect, increases the luminous output for a given power input and consequently increases the 

lamp efficacy. One way to increase the filament temperature is by increasing the wattage of the 

lamp. As a higher current passes through and a high voltage drop occurs over the filament, the 

amount of energy released in the form of heat increases, thereby raising the temperature. 

However, this significantly changes the luminous output of the lamp and may not meet the 

consumer’s needs. Other technologies that address a lamp’s ability to operate at high 

temperatures are filament thickness, inclusion of inert gas fills, and the use of halogen fills, all 

discussed below. In addition to efficacy, the change in operating temperature also affects color 

appearance and lifetime of the lamp. As Figure 3.4.9 shows, increasing color temperature is a 

direct effect of, but not equivalent to, raising operating temperature and also causes an increase 

in luminous efficacy. 

Figure 3.4.8 Radiating Characteristics of Tungsten 

Source: IESNA Lighting Handbook: Reference & Application 32

 

o

 In this graph, Curve A and Curve B’ are not strictly relevant to this point, and represent the radiant flux from one 

square centimeter of a blackbody at 3,000 K and the radiant flux from 2.27 square centimeters of tungsten at 3,000 

K, respectively. 
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Figure 3.4.9 Luminous Efficacy versus Color Temperature 

Source: IESNA Lighting Handbook: Reference & Application 33

At the melting temperature of tungsten, 6,120 °F, the maximum efficacy of an 

incandescent lamp with an uncoiled tungsten filament is 53 lm/W. However, to obtain long life 

in an incandescent lamp, the filament temperature should be significantly below its melting 

point. As the filament burns hotter, more tungsten evaporates from the filament. When the 

filament eventually breaks, the lamp fails. This is an example of the clear tradeoff between lamp 

efficacy and lamp lifetime. Also, to maintain the cool bulb surface, high temperature 

incandescent lamps often require larger bulbs. This affects the fixtures in which they fit. 

3.4.4.2 Novel Filament Materials 

Tungsten is a commonly used filament material. However, other filament materials can 

be considered. In choosing a filament, some advantageous properties are high melting point, low 

vapor pressure, high strength, high ductility, and good radiating characteristics. While tungsten is 

primarily used for incandescent lamps, manufacturers also incorporate other metals such as 

rhenium to improve ductility. However, these lamps are most commonly used for applications 

requiring vibration-resistant lamps. Novel filament materials, such as nitrides and carbides, have 

the potential to improve lamp efficacy by emitting more light in the visible spectrum at a given 

temperature than traditional tungsten filaments. However, these novel filaments can also be 

brittle, an attribute that can shorten the lamp lifetime. 

3.4.4.3 Thinner Filaments 

A thinner filament has an increased resistance and therefore an increased operating 

temperature. As previously discussed, a higher operating temperature results in a higher lamp 

efficacy. However, as an adverse effect, an incandescent lamp with a thinner filament cannot 

withstand as much tungsten evaporation as a thicker filament before failing, resulting in a shorter 

lifetime. 
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3.4.4.4 Efficient Filament Placement 

Placement of the filament is an important aspect of incandescent reflector design. The 

placement of the filament is optimal when a portion of the spectrum emitted by the filament is 

focused back onto the filament. This additional radiation supplies heat to the filament and the 

operating temperature increases. As discussed earlier, an increase in operating temperature 

results in a higher light output and therefore an increase in efficacy. 

3.4.4.5 Efficient Filament Orientation 

 Tungsten filament in incandescent lamps can be positioned horizontally or vertically with 

respect to the base of the bulb. Because the light emitted from the filament is distributed in all 

directions, one way to improve efficacy is by designing the lamp in a way such that the most 

amount of light is able to escape the bulb. By positioning the filament in a horizontal orientation, 

the base of the lamp absorbs much of the emitted light along the length of the coil. However, by 

positioning the filament in vertical alignment, only a small portion of the light is emitted towards 

the base. Consequently, more light escapes the bulb and is used for illumination. This can 

increase the efficacy of an incandescent lamp by approximately eight percent. In most IRLs on 

the market, the filament is vertically positioned. 

3.4.4.6 Efficient Filament Coiling 

Coiling of the incandescent lamp filament can increase luminous efficacy. The light 

output of an incandescent lamp is directly proportional to the light-emitting surface area of the 

light source. By coiling the filament, a longer filament can be used, increasing luminous output 

and therefore lamp efficacy. Coiling of the tungsten also affects the heat loss from the filament. 

The more the filament is coiled, the less the effective area for convective cooling, thereby 

increasing filament temperature and lamp efficacy. IRLs covered in this rulemaking generally 

contain filaments of the type C (coiled) or CC (coiled coil). The highly efficacious CC type 

filament, which is more commonly used, consists of the coil wound into another helical coil. 

3.4.4.7 Microcavity Filaments 

Texturing of the filament surface can increase surface area and therefore emissivity. 

Filament surface perforations also can act as waveguides for visible light. One technology 

includes the creation of microcavity holes in the filament surface. The cavities may then be filled 

with materials such as tantalum, rhenium, molybdenum, tungsten, SiC, rare earth elements, glass 

beads, or any combination thereof. Depending on their fabrication, this technology can result in a 

variety of effects such as greater control of emissive direction, reduction of infrared radiation, 

and increased emission efficiency over a certain bandwidth of wavelengths. Ultimately, these 

effects produce a higher overall efficacy. Research indicates that materials patterned at the 

submicron level may experience problems with stability.34

3.4.4.8 Crystallite Filament Coatings 

A variety of filament coatings may be used to increase the efficacy of incandescent 

lamps. Layers of micron or submicron crystallites, comprised of thorium, tantalum, and/or 

niobium, are deposited on the filament surface. The crystallites are coated with a protective layer 

of at least one oxide of thorium, hafnium, scandium, yttrium, cerium, or zirconium. This coating 

increases the emissivity of the filament in the visible part of the spectrum without increasing the 
3-37

infrared radiation. However, as the operating temperature of the filament increases, the 

emissivity improvement due to the crystallites decreases. Iridium may also be used as a coating 

to recycle wasted heat. 

3.4.4.9 High Reflectance Filament Supports 

In a tungsten-halogen capsule, tungsten filament supports can include a reflective face 

that reflects light to another filament, the reflective face of another filament support, or radially 

outward, thereby increasing light output/emissivity, and thus efficacy, by providing light that 

otherwise would have been wasted. The filament supports could also include grooves or an 

emissive coating with a high emissivity to increase heat dissipation or be formed of a porous 

ceramic material to increase efficiency. 

3.4.4.10 Higher Efficiency Inert Fill Gas 

IRLs covered in this rulemaking typically are filled with an inert fill gas whose primary 

purpose is to reduce the evaporation of tungsten, preventing bulb blackening and increasing 

lifetime. In addition, this fill gas increases the pressure inside the bulb or halogen capsule. The 

fill gas also provides a means of convective heat transfer between the heated filament and cool 

bulb surface. This cooling of the filament represents a power loss and an efficacy reduction due 

to low temperature operation. Krypton’s low thermal conductivity decreases the convective 

cooling of the filament, allowing for higher temperature operation and therefore higher efficacy. 

In addition, because the krypton molecule is larger than other elements, such as argon, krypton 

more effectively slows the evaporation of tungsten and therefore extends the life of the lamp. 

Xenon, having even lower heat conductivity and larger mass than krypton, can more drastically 

change efficacy and life but also at a greater cost. Most lamps compliant with the July 2012 

standards use xenon as a fill gas.

3.4.4.11 Higher Pressure Tungsten-Halogen Lamps 

Increasing the pressure of the halogen capsule by increasing the density of halogen 

elements can indirectly raise the efficacy of the tungsten-halogen lamp. The increased density of 

halogen elements raises the probability that an evaporated tungsten element combines with a 

halogen element in a gaseous compound. Adding more of this gaseous compound in the capsule 

effectively increases the amount of tungsten re-deposited on the tungsten filament. This can be 

used to lengthen the lifetime of the tungsten-halogen lamp by decreasing the evaporation rate of 

tungsten if the filament temperature is unchanged, or raise its efficacy by increasing the filament 

temperature while maintaining the evaporation rate of tungsten. A combination of increased 

lifetime and efficacy may be achieved if the temperature is partially increased and the tungsten 

evaporation rate is partially decreased. 

3.4.4.12 Non-Tungsten-Halogen Regenerative Cycles 

The regenerative cycle of filament evaporation and redeposition (where the filament 

material evaporates and combines with halogen into a gaseous compound and then redeposits on 

the filament when it contacts it again because the heat of the filament breaks the compound) can 

be used to greatly increase the life of an incandescent lamp. The filament can burn at a higher 

temperature than conventional incandescent lamps while maintaining a useful service life. 
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Implementation of a non-tungsten-halogen regenerative cycle depends on incorporating a nontungsten filament. 

3.4.4.13 Infrared Glass Coatings 

Infrared coatings on incandescent lamps are used to reflect some of the radiant energy 

emitted back onto the filament. This infrared radiation then supplies heat to the filament and the 

operating temperature increases. As discussed earlier, an increase in operating temperature 

results in a higher light output and therefore an increase in efficacy. In addition, the spectrum of 

the incandescent lamp shifts toward shorter wavelengths, increasing its overlap with the photopic 

spectral eye sensitivity and subsequently increasing efficacy for a given power input. These 

infrared coatings can be in many forms, with new coating types continuing to be developed. 

Examples include multilayer dichroic filters and crystal lattice structures whose spacing defines a 

photonic bandgap. They can be applied directly to the glass halogen capsule for tungsten-halogen 

lamps. However, they are most commonly used in the coating of the halogen capsule, which 

achieves the greatest directed reflection back onto the filament for the lowest infrared coating 

usage. Because the halogen capsule is most traditionally in the shape of a cylinder, when infrared 

coatings are applied to a halogen lamp, the cylindrical shape helps direct the light reflected from 

the coatings. 

3.4.4.14 Higher Efficiency Reflector Coatings 

As mentioned previously, IRLs are incandescent lamps with a reflective coating, most 

commonly composed of aluminum or silver applied directly to the reflector surface. The reflector 

coating allows these lamps to place the same illuminance on a specific area with reduced watts, 

thereby increasing efficacy. Though aluminum is most prevalent as a reflector coating in IRLs, 

silver coatings can also be applied. While aluminum coatings are applied internally by 

condensation of vaporized aluminum on the inner surface of the bulb, silver can be applied both 

on the interior and exterior surfaces of the bulb. When applied externally, the silver coating is 

protected by a copper coating and aluminum finish. Silver coatings are generally preferred over 

aluminum due to their lower light loss. Gold is also extremely reflective and can be used to 

increase the amount of directed light and therefore efficacy of the lamp. Mentioned previously as 

a technology option, an infrared glass coating that reflects the infrared radiation back toward the 

lamp’s filament is also a type of higher efficiency reflector coating. This infrared reflector 

coating, in the form of multilayer dichroic filters or crystal lattice structures, ultimately increases 

lamp efficacy by limiting the amount of energy lost through infrared radiation and by increasing 

lamp operating temperature. 

3.4.4.15 Permanent Infrared Reflector Coating Shroud 

Infrared glass coatings on capsules can represent a significant portion of manufacturing 

costs and are usually disposed of when the lamp dies. However, use of a permanent shroud with 

an infrared reflector coating and a removable and replaceable lamp can increase efficiency while 

reducing manufacturing costs. The shroud contains a substrate and infrared reflector coating to 

reflect light back to the filament, thereby increasing efficacy by increasing the operating 

temperature and shifting the spectrum toward shorter wavelengths, as discussed previously. The 

shroud and lamp can be configured to be optimally aligned with the lamp reflector. 
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3.4.4.16 Infrared Phosphor Glass Coating 

Salts of the rare earths and other transition group elements contain ions at energy levels 

that are particularly suited to emit visible light when in transition.35 In the presence of infrared 

light, these ions will jump to higher energy levels. In some cases, when the ions fall to lower 

energy levels, light in the visible spectrum is emitted. When used as a coating on a bulb surface, 

infrared phosphors are able to harvest the emitted infrared energy and convert it to visible light, 

potentially increasing lamp efficacy. 

3.4.4.17 Ultraviolet Phosphor Glass Coating 

Similar to infrared phosphor glass coatings, phosphor materials exist that are capable of 

absorbing high energy radiation and reemitting it at a lower energy level. Specifically, these 

phosphors convert radiation in shorter wavelengths (UV, violet, and blue spectrums) into longer 

wavelengths (green and yellow spectrums) of light. The human eye is most responsive to green 

and yellow visible light, so lumen output is increased by approximately three percent since 

lumens are weighted by the photopic spectral eye sensitivity. 36 37

3.4.4.18 Corner Reflectors 

Due to the shape of many reflector lamps, infrared lens technologies can be incorporated 

in the cover glass to direct infrared radiation back onto the filament. Conventional infrared 

coatings on reflector lamps direct the infrared light back into the bulb, but not directly onto the 

filament. Other parts of the lamp absorb some of this heat, which is therefore a source of energy 

loss. A corner reflector is a technology that incorporates individual corner reflectors into the 

cover glass. These reflectors’ shapes provide the unique ability to reflect light directly back in 

the direction it came. Therefore any light coming from the filament and impinging on the cover 

glass will be directed straight back to the filament. These reflectors are covered with a dichroic 

coating, allowing visible light to pass through and escape while causing infrared radiation to 

reflect back on the filament. As this radiation heats the filament, the lamp requires less input 

power to operate at a higher operating temperature, and therefore operates more efficaciously. 

3.4.4.19 Electron Stimulated Luminescence 

In a process known as cathodoluminescence, visible light can be generated when 

accelerated electrons strike a phosphor surface. Incandescent filaments produce electrons by 

thermionic emission. A low voltage cathodoluminescent phosphor that emits green light upon 

impingement by these thermally ejected electrons may be applied to the lamp. The technology 

increases light ouput by utilizing electrons to emit visible light, which otherwise would not have 

been produced. This phenomenon can be enhanced by the presence of a lamp fill gas, which may 

increase the available current for cathode-ray excitation of the phosphor. 

3.4.4.20 Integrally Ballasted Low Voltage Lamps 

The use of an integral ballast in an incandescent lamp allows an increase in the efficacy 

because it operates at low voltages, though it is used in a socket with main line voltage (i.e., it 

converts the operating voltage of the lamp to a lower wattage from line voltage). The conversion 

of line voltage to lower lamp operating voltages has associated energy losses. However, modern 

integral ballast technologies allow efficacy gains from low-voltage operation to outweigh any 

such conversion losses. 
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3.5 PRODUCT CLASSES 

When evaluating and establishing energy conservation standards, DOE divides covered 

products into classes by (a) the type of energy used; (b) the capacity of the product; or (c) other 

performance-related features that justify different standard levels, such as features affecting 

consumer utility. (See 42 U.S.C. 6295(q)) DOE then conducts its analysis and considers separate 

standard levels for each product class. DOE applied the criteria of 42 U.S.C. 6295(q) to GSFLs 

and IRLs to develop product classes in this preliminary analysis. This section of the TSD 

describes the factors DOE examined in considering product classes for GSFLs and IRLs. 

3.5.1 General Service Fluorescent Lamps 

In setting energy conservation standards for fluorescent lamps, EPAct 1992 established 

product classes based on its definition for fluorescent lamps and on nominal lamp wattages. 

EPAct 1992 set two classes for each lamp type, making a total of eight product classes, as shown 

in Table 3.5.1. (42 U.S.C. 6295(i)(1)(B)) 

Table 3.5.1 EPAct 1992 Product Classes for General Service Fluorescent Lamps 

Lamp Type Nominal Lamp Wattage 

4-foot medium bipin > 35 W 

4-foot medium bipin ≤ 35 W 

2-foot U-shaped > 35 W 

2-foot U-shaped ≤ 35 W 

8-foot single pin slimline > 65 W 

8-foot single pin slimline ≤ 65 W 

8-foot recessed double contact high output > 100 W 

8-foot recessed double contact high output ≤ 100 W 

The 2009 Lamps Rule redefined these product classes, establishing divisions based on 

physical constraints of lamps (i.e., lamp shape and lamp length), lumen package (i.e., SO versus 

HO), and CCT, as shown in Table 3.5.2.

Table 3.5.2 GSFL Product Classes from the 2009 Lamps Rule 

Lamp Type CCT

4-foot medium bipin ≤4,500 K

>4,500 K

2-foot U-shaped ≤4,500 K

>4,500 K

8-foot single pin slimline ≤4,500 K

>4,500 K

8-foot recessed double contact high output ≤4,500 K

>4,500 K

4-foot T5, miniature bipin standard output ≤4,500 K

>4,500 K

4-foot T5, miniature bipin high output ≤4,500 K

>4,500 K

For this preliminary analysis DOE examined several possible characteristics or features of 

GSFLs that could warrant separation of covered products into different product classes, 

including: 
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 physical constraints of lamps (i.e., lamp shape and lamp length), 

 lumen package (i.e., regular versus HO), 

 diameter, 

 CCT, 

 interoperability of lamps on the same ballast system, 

 wattage, and 

 CRI. 

 The following subsections discuss these lamp attributes and how they pertain to product 

class divisions. 

3.5.1.1 Physical Constraints of Fluorescent Lamps 

The physical constraints of the lamp relate to its shape and length. Because consumers 

must change a lamp fixture to substitute lamps of different geometries for one another, lamp 

shape affects utility. DOE research and interviews with manufacturers found that these physical 

differences prohibit direct replacement. For example, a U-shaped lamp cannot substitute for a 

linear-shaped lamp in the same fixture. Similarly, given their metric lengths, T5 lamps cannot be 

used as direct replacements for T8 lamps in some applications. These lamps require different 

lamp holders (due to differences in length and base type). Further, a 4-foot lamp may have a 

different utility than an 8-foot lamp, as these lamps generally require different fixtures. 

In addition, a lamp’s geometry also affects its efficacy. For example, efficacy tends to 

increase with length. All else being equal, 8-foot lamps generally have higher efficacy values 

than 4-foot lamps. Also, a 2-foot U-shaped lamp, while having the same overall tube length, is 

less efficacious than a 4-foot linear lamp, partly because the electrical arc within the tube has to 

bend to conform to the lamp shape. Given the impact that geometry has on both utility and 

efficacy, DOE is considering establishing separate product classes based on lamp geometry. 

DOE also conducted an analysis to determine if different lamp base types affect efficacy. 

DOE found that it was unable to isolate base type alone while holding all other characteristics 

equal. This is because base type is dependent on a combination of lamp characteristics, 

specifically length, diameter, and lumen package. Therefore, DOE was unable to determine if 

base type alone impacted efficacy. However, because base type is already accounted for when 

considering the product class divisions of length and lumen package, DOE determined no further 

division is needed.

3.5.1.2 Lumen Package 

 Lumen package refers to the quantity of light that a lamp-and-ballast system provides to a 

consumer. DOE observed that consumers tend to use systems with different lumen packages for 

different applications. For example, high-lumen-output systems may be installed in certain highceiling or outdoor applications, where large quantities of light are needed. Alternatively, 

standard-lumen-output systems might be installed in lower-ceiling applications such as offices or 

hospitals, where, for example, distance between the light source and the illuminated surfaces is 
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not as large. These notable differences in the application of SO versus HO lamps indicate a 

difference in utility. 

 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 MiniBP HO 

lamps tend to operate at higher currents than 8-foot SP slimline lamps and 4-foot MiniBP SO 

lamps, respectively. This difference in operating design increases the quantity of light per unit 

lamp length for the 8-foot RDC HO and 4-foot MiniBP HO lamps. Operating lamps at a higher 

current also decreases efficacy. For example, the efficacy of an 8-foot RDC HO lamp is as much 

as 10 percent lower than that of a comparable 8-foot SP slimline lamp. Given the observed utility 

distinctions and notable efficacy differences between SO and HO lamps, DOE is considering 

establishing separate product classes based on lumen package. 

3.5.1.3 Diameter 

As discussed in section 3.4.2.5, lamp diameter is a feature of a lamp which impacts 

efficacy. In general, DOE considers lamp diameter as a design option, and did not consider using 

it as a basis for developing product classes. Manufacturer marketing literature and general 

guidance on lighting design and installation often promote T8 lamp-and-ballast systems as higher 

efficacy, energy-saving substitutes for T12 lamp-and-ballast systems. Such substitute systems 

have the same lengths and bases, offer comparable lumen output, and can fit within the same 

fixtures. Therefore, DOE recognizes that although the diameter of the lamp will affect the 

efficacy, the utility provided to the end-user is comparable and/or equivalent. 

As stated earlier, DOE generally considers lamp diameter a design option when there is 

no associated decrease in utility. However, DOE will consider separate product classes for 

different diameter lamps when there is a decrease in utility, such as with the T5 MiniBP lamps. 

DOE’s test procedure for GSFLs requires lamps to be tested using low frequency reference 

ballast settings unless only high frequency settings are available. Because only high frequency 

settings are available for T5 lamps, these lamps are tested under different conditions than T8 

lamps. High frequency operation increases lamp lumen output; thus, T5 lamps appear to be more 

efficacious than similar T8 lamps. If T5 and T8 lamps were included in the same product class, 

T8 lamps could be eliminated due to this difference in efficacy. T8 lamps, however, provide 

consumer utility because more lumen packages are available for T8 than for T5 lamp-and-ballast 

systems. Consumers tend to use systems with different lumen packages for different applications. 

Most of the commercially available 4-foot T5 MiniBP SO lamps offer the same initial lumen 

output. Specifically, 80 percent of standards-compliant 4-foot T5 MiniBP SO lamps have an 

initial lumen output of 2900 lumens.p On the other hand, 4-foot MBP T8 lamps offer a much 

wider range of initial lumen outputs. Additionally, fluorescent lamps are a component of a 

system and their performance characteristics are related to the ballast on which they operate. 

Each fluorescent lamp ballast has a specified BF, which is typically used to adjust the lumen 

package of a lamp-and-ballast system. The vast majority of ballasts designed to operate 4-foot 

T5 MiniBP SO lamps have normal BFs, which further limits lumen package options for these 

systems. Ballasts that operate 4-foot MBP T8 lamps, however, are available with a larger range 

 

p

 Data in catalogs is often reported at 35 °C. 
3-43

of BF options (i.e., low, normal, and high). Thus, a standard that eliminates 4-foot MBP T8 

lamps would result in a substantial decrease in available lumen package options and negatively 

impact consumer utility. 

Further, a standard which eliminates 4-foot T8 MBP lamps could result in increased 

system energy consumption. As mentioned above, the vast majority of commercially available 

ballasts designed to operate 4-foot T5 MiniBP SO lamps are normal BF PS ballasts with a typical 

BF of 1.0. The most common BF for ballasts of the same starting method (PS) designed to 

operate 4-foot T8 MBP lamps is 0.88. Although the high frequency reference arc power of full 

wattage 4-foot T5 MiniBP SO lamps is lower than the high frequency reference arc power of full 

wattage 4-foot T8 MBP lamps (27.8 W and 29.0 W, respectively), the higher BF of T5 SO 

ballasts results in higher overall system energy consumption compared to the typical T8 MBP 

system. 

Therefore, due to the effect of diameter on both efficacy and utility, and the potential for 

increased energy consumption, DOE establishes separate product classes for 4-foot T5 MiniBP 

lamps. 

3.5.1.4 Correlated Color Temperature 

As discussed in section 3.3.1.3, in general terms, the CCT is a measure of the perceived 

color of the white light emitted from the lamp. The perception of light affords consumers a 

different utility for lamps with different CCT values. Additionally, as the SPD of the lamp is 

modified to change the CCT, the lamp efficacy can vary. Due to their greater blue light content, 

higher CCT fluorescent lamps tend to have lower efficacies. 

For covered fluorescent lamps, CCT ranges span between 2,500 K and 7,000 K. 

Feedback from manufacturer interviews indicates that lamps with CCTs greater than 4,500 K 

begin to show a considerable decline in efficacy. Given the impact on efficacy and utility, DOE 

is considering establishing separate product classes for lamps with CCT less than or equal to 

4500 K and greater than 4500 K.

3.5.1.5 Ballast Interoperability 

Not all lamps operate on the same ballast. Even if lamps have similar geometries, 

different ballasts may be required for their operation. However, DOE treats ballast 

interoperability as an economic issue (in the life-cycle cost and national impact analyses) rather 

than a product class issue. In other words, if a consumer needs to change the ballast to replace a 

lamp, then the installed cost of both the lamp and ballast are factored into the net present value 

equation. Therefore, DOE will not be establishing a product class division based on ballast 

interoperatbility.

3.5.1.6 Wattage 

 The main function of a lamp is to provide lumen output, while other attributes such as 

CCT, for example, contribute to utility. Wattage measures the power consumed by a lamp in 

providing its service. Therefore, DOE does not construe wattage as a direct measurement of 

utility, which is the criteria prescribed by 6295(q) for structuring product classes. 
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Furthermore, dividing product classes by wattage locks the standards for GSFLs to a 

static wattage structure. While this structure may reflect current product availability, the market 

may evolve over time, shifting to different wattages. Therefore, DOE will not be establishing 

product classes based on wattage. 

3.5.1.7 Color Rendering Index 

DOE also considered setting product classes for GSFLs based on CRI. DOE analyzed the 

impact of CRI on efficacy when keeping all other lamp characteristics constant. DOE found no 

correlation between CRI and efficacy and therefore concluded that CRI did not have a direct 

impact on efficacy. DOE did confirm, however, that the majority of lamps with higher efficiency 

phosphors also offered higher CRIs as discussed in section 3.4.2.3. For example, lamps with 

800-series rare earth phosphors, considered the most efficient combination of phosphors, had the 

highest CRI values typically ranging from 80 to 86. However, there was no indication of 

consistently increasing efficacy with increasing CRI values for the lamps within each specific 

phosphor series. 

 DOE recognizes that CRI provides utility because a high CRI light source renders colors 

well and can be required for color sensitive applications. Although CRI is associated with a 

change in utility, because DOE found no direct impact on efficacy associated with CRI, DOE 

will not be establishing separate product classes based on CRI. 

3.5.1.8 Product Class Summary 

DOE is considering maintaining the same product class divisions as those established in 

the 2009 Lamps Rule. The GSFL product classes being considered in this preliminary analysis 

are summarized in Table 3.5.3.

Table 3.5.3 GSFL Preliminary Analysis Product Classes 

Lamp Type CCT

4-foot medium bipin ≤4,500 K

>4,500 K

2-foot U-shaped ≤4,500 K

>4,500 K

8-foot single pin slimline ≤4,500 K

>4,500 K

8-foot recessed double contact high output ≤4,500 K

>4,500 K

4-foot T5, miniature bipin standard output ≤4,500 K

>4,500 K

4-foot T5, miniature bipin high output ≤4,500 K

>4,500 K

3.5.2 Incandescent Reflector Lamps 

 In setting energy conservation standards for IRLs, EPAct 1992 differentiated IRLs by 

wattage and established six nominal wattage ranges or “bins,” shown in Table 3.5.4. (42 U.S.C. 

6295(i)(1)(B)) 
3-45

Table 3.5.4 EPAct 1992 Product Classes for Incandescent Reflector Lamps 

Nominal Lamp Wattage 

40-50 

51-66 

67-85 

86-115 

116-155 

156-205 

The 2009 Lamps Rule redefined these product classes, establishing divisions based on lamp 

diameter, voltage, and spectrum. DOE is considering maintaining these divisions, as shown in 

Table 3.5.5. 

For this preliminary analysis DOE examined several possible characteristics or features of 

IRLs that could warrant separation of covered products into different product classes, including: 

 wattage, 

 spectrum, 

 diameter, 

 voltage, 

 beam spread, 

 center beam candle power, and 

 length. 

 The following subsections discuss these lamp attributes and how they pertain to product 

class divisions. 

Table 3.5.5 IRL Product Classes from the 2009 Lamps Rule 

Lamp Type Diameter

(in inches) Voltage

Standard Spectrum > 2.5 ≥125 V

<125 V

≤ 2.5 ≥125 V

<125 V

Modified Spectrum > 2.5 ≥125 V

<125 V

≤ 2.5 ≥125 V

<125 V

3.5.2.1 Wattage 

Lamp wattage does impact efficacy. However, as with GSFLs, DOE does not consider 

wattage as a direct measure of utility. Furthermore, a product class structure that encompasses all 

wattages can better keep pace with the market should it shift to new wattages over time. As 

wattage increases for incandescent lamps, efficacy also generally increases. To use a single range 

of wattages while taking into account variation in efficacy by wattage, DOE has developed a 
3-46

single standard per product class as an equation that relates lumens to wattage and sets a 

minimum efficacy requirement that varies by wattage. Chapter 5 of this TSD provides more 

information on the selection of candidate standard levels using this equation.

3.5.2.2 Spectrum

Modified spectrumq IRLs provide unique utility to consumers by providing a different 

type of light than standard spectrum lamps, much like fluorescent lamps with different CCT 

values. However, the same technologies that modify the spectral emission of a lamp also 

decrease lamp efficacy. To modify the spectrum, the coating absorbs a portion of the light 

emission from the filament. Neodymium coatings or other coatings on modified spectrum lamps 

absorb some of the visible emission from the incandescent filament (usually red), creating a 

modified, reduced spectral emission. Since the neodymium or other coatings absorb some of the 

lumen output from the filament, these coatings decrease the efficacy of the lamp. 

 Because of the impact on both efficacy and utility, DOE is considering establishing 

separate product classes based on spectrum. DOE is planning to establish separate product 

classes for standard spectrum IRLs (those without modification to the spectral emission) and 

modified spectrum IRLs (some portion of the spectral emission is absorbed). 

3.5.2.3 Diameter 

 IRL diameter provides a distinct utility to the consumer, such as the ability to be installed 

in smaller fixtures. The diameter of an IRL also has an impact on its efficacy. Smaller diameter 

lamps have an inherently lower optical efficiency than larger diameter lamps with similar 

filaments. Additionally, technology options that improve efficacy that are available to larger 

lamps are not necessarily available to small diameter lamps given the spatial constraints. 

Therefore, because of the impact on both efficacy and consumer utility, DOE is considering 

establishing separate product classes for lamps with a diameter of 2.5 inches or less and lamps 

with a diameter greater than 2.5 inches. 

3.5.2.4 Rated Voltage 

 Existing DOE test procedures provide for lamps rated at 130 V to be tested at 130 V and 

for lamps rated at 120 V to be tested at 120 V. However, DOE is aware that a large number of 

consumers actually operate 130 V lamps at 120 V, which results in longer lifetime but lower 

efficacy. With a single efficacy level (EL) for lamps rated at each voltage, this situation would 

 

q

 As found in 10 CFR 430.2: 

Modified spectrum means, with respect to an incandescent lamp, an incandescent lamp that— 

(1) Is not a colored incandescent lamp; and 

(2) When operated at the rated voltage and wattage of the incandescent lamp— 

(A) Has a color point with (x,y) chromaticity coordinates on the C.I.E. 1931 chromaticity diagram, figure 2, 

page 3 of IESNA LM-16 (incorporated by reference; see § 430.3) that lies below the black-body locus; and 

(B) Has a color point with (x,y) chromaticity coordinates on the C.I.E. 1931 chromaticity diagram, figure 2, 

page 3 of IESNA LM-16 (incorporated by reference; see § 430.3) that lies at least 4 MacAdam steps, as 

referenced in IESNA LM-16, distant from the color point of a clear lamp with the same filament and bulb 

shape, operated at the same rated voltage and wattage. 
3-47

effectively lead to a lower efficacy requirement for these 130 V lamps that are run at 120 V, 

compared to 120 V lamps run at 120 V. The 130 V lamps would not require the same level of 

technology as 120 V lamps to meet the same standard, and, thus, they would be cheaper to 

produce. Therefore, setting higher standards for IRLs without accounting for voltage differences 

could result in increased migration to 130 V lamps instead of the 120 V lamps, which could 

increase energy consumption. 

 For example, if DOE were to adopt a minimum efficacy requirement that would 

effectively require improved halogen infrared reflector (HIR) technology for 120 V lamps, due to 

differences in the test procedures for lamps rated at 130 V, a 130 V lamp may only need to 

employ an improved halogen technology, which would be less costly. If DOE does not establish 

a separate standard for lamps rated at 130 V, more consumers may purchase 130 V lamps 

because they are less expensive. When consumers operate these lamps at 120 V, they may need 

to purchase more lamps to obtain sufficient light output, thereby increasing energy consumption. 

Therefore, to preserve the energy savings intended by these standards, DOE is considering 

establishing two separate product classes: (1) lamps with a rated voltage less than 125 V, and (2) 

lamps with a rated voltage greater than or equal to 125 V.

3.5.2.5 Beam Spread 

DOE considered setting product classes for IRLs based on beam spread values or beam 

spread categories (spot, flood, narrow flood, etc.). DOE conducted an analysis to determine if 

beam spread impacted efficacy by comparing lamps with the same characteristics but different 

beam spreads. DOE concluded that while there might be different utility for consumers through 

the light distribution patterns of lamps with different beam spreads, the beam spread does not 

affect the efficacy of the lamp. Thus, DOE does not plan to establish separate product classes for 

beam spread. 

3.5.2.6 Center Beam Candle Power 

Center beam candle power (CBCP) provides a measure of the light intensity at the center 

of an angle and is correlated to beam spread. DOE conducted an analysis to determine if CBCP 

impacted efficacy by comparing lamps with the same characteristics but different CBCP values. 

DOE concluded that while there might be different utility for consumers through the variation in 

light intensity between lamps with different CBCP values, the CBCP does not affect the efficacy 

of the lamp. Thus, DOE does not plan to establish separate product classes for CBCP. 

3.5.2.7 Length 

DOE considered setting product classes for IRLs based on maximum overall length of the 

lamp. DOE conducted an analysis to determine if length impacted efficacy by comparing lamps 

with the same characteristics, but different lengths. DOE was unable to confirm a relationship 

between length and efficacy. DOE concluded that while there may be a certain consumer utility 

for lamps with different lengths, the efficacy impact did not justify establishing product classes 

based on length. 
3-48

3.5.2.8 Product Class Summary 

DOE is considering maintaining the same product class divisions as those established in 

the 2009 Lamps Rule. The IRL product classes being considered in this preliminary analysis are 

summarized in Table 3.5.6.

Table 3.5.6 IRL Preliminary Analysis Product Classes 

Lamp Type Diameter

(in inches) Voltage

Standard Spectrum > 2.5 ≥125 V

<125 V

≤ 2.5 ≥125 V

<125 V

Modified 

Spectrum

> 2.5 ≥125 V

<125 V

≤ 2.5 ≥125 V

<125 V
3-49

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